Income Tax : This document provides a complete reference on compounding of offences, including application procedures, offence-wise charges, re...
Income Tax : The FAQs explain the revised CBDT guidelines on compounding offences under the Income-tax Act effective from 17 October 2024. They...
Income Tax : The FAQs explain the prosecution provisions under the Income-tax Act, covering offences such as tax evasion, non-payment of TDS/TC...
Income Tax : Judicial rulings clarify that satisfaction for initiating action against other persons in search cases must be recorded promptly. ...
Income Tax : Courts are divided on whether the DRP-specific deadline under Section 144C(13) overrides the general assessment time bar in Sectio...
Income Tax : Learn about the new block assessment provisions for cases involving searches under section 132 and requisitions under section 132A...
Income Tax : ITAT Delhi quashed a Section 153C assessment, holding that a consolidated and defective satisfaction note invalidated jurisdiction...
Income Tax : ITAT held that a registered sale deed without corroborative evidence is not incriminating material and cannot support additions in...
Income Tax : ITAT held reassessment under Sections 147/148 invalid because it was based on a pre-1 April 2021 third-party search, requiring pro...
Income Tax : ITAT Mumbai quashed a Section 148 notice issued after the limitation under the first proviso to Section 149, holding the reassessm...
Income Tax : ITAT held that penalty under Section 271D cannot survive where the Assessing Officer failed to record satisfaction in the assessme...
Income Tax : Availability of Miscellaneous Functionalities related to ‘Selection of Case of Search Year’ and ‘Relevant Search...
Once an appellate authority like the Commissioner (Appeals) or the ITAT deleted a tax addition and assessee’s liability stood discharged, the Tax Recovery Officer was bound to give effect to such order and lift the attachment.
DCIT Vs Indian Hydro Electric Power Pvt. Ltd. (ITAT Delhi) No Incriminating Evidence, Only Excel — ITAT Deletes ₹25 Cr Addition in Moser Baer Group Case Search was conducted on the Moser Baer Group, covering Assessee’s premises. During search, an Excel sheet titled “Funds Position” was found on a group employee’s laptop, showing loan entries. […]
The ITAT Delhi held that additions under Section 153A cannot be made without incriminating material found during search and set aside assessments for AYs 2013–14 and 2014–15.
ITAT Delhi held that reassessment for AY 2010-11 was invalid since it exceeded the ten-year limitation from the search year. The notice was declared time-barred and issued without jurisdiction.
TAT Delhi held that a 153C assessment for AY 2012–13 was invalid, as the six-year block must be counted from date of satisfaction recorded by AO of non-searched person.
ITAT Delhi held that ten-year block under Section 153C must be computed from date AO of non-searched person receives seized material, not search date.
ITAT Delhi held that assessments for A.Ys 2011–12 and 2012–13 were invalid since they fell outside the ten-year block reckoned from the date of receipt of seized material. The Tribunal followed CIT v. Jasjit Singh (SC) and Ojjus Medicare (Del HC) rulings.
ITAT Delhi held that a seized document mentioning ₹18 lakh could not, without corroboration, be treated as undisclosed income of Krishna Gopal Saraf, deleting the addition.
The ITAT held that the Assessing Officer cannot discard a registered valuer’s report without referring the matter to a Departmental Valuation Officer. The AO’s addition was set aside, and the fair market value must be recomputed based on the valuer’s report.
The ITAT Delhi deleted additions made under Section 153A for unabated/completed assessment years (AYs 2013-14 to 2016-17) following a search. The ruling strictly applied the Supreme Court’s mandate in Abhisar Buildwell that additions in completed years require the finding of incriminating material during the search.
