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...
ITAT Mumbai held that levy of penalty under section 270A of the Income Tax Act cannot be sustained since specific limb of Section 270A(9) leading to under-reporting of income or mis-reporting of income is not specified. Accordingly, appeal of assessee is allowed.
Madras High Court held that Tax Recovery Officer needs to lift attachment of the property based on orders passed by the highest fact finding authority has attained finality and there is no payment pending on the part of the assessee.
ITAT Dehradun held that penalty u/s 271(1)(c) was invalid as the AO failed to specify whether it was for concealment or inaccurate particulars, showing lack of application of mind.
ITAT Delhi ruled that WhatsApp chats recovered during a search, if corroborated by context and left unrebutted by the assessee, create a statutory presumption of correctness under Section 292C, leading to a sustained addition of ₹9 lakh as unexplained money. The Tribunal also directed the allowance of an 80TTA deduction claim for the abated assessment year (AY 2018-19).
ITAT Delhi held that no addition can be made u/s 153A of the Income Tax Act without there being any incriminating material relating to unabated assessment year. Therefore, additions made in the assessment order is deleted and appeal is partly allowed.
Tribunal upheld CIT(A)’s view that assessments for AYs 2013-14 to 2015-16 fell outside permissible six-year block under Section 153C. Additions made by AO were held time-barred and without jurisdiction.
ITAT Delhi dismissed the Revenue’s appeal, ruling that the assessment under Section 153C was time-barred because the block period must be calculated from the date the Assessing Officer (AO) of the non-searched person received the seized material. The ruling confirms that the date of the original search is irrelevant for non-searched persons.
ITAT Delhi set aside 43 search assessments involving a business group and its associates, ruling that the mass approvals granted under Section 153D were invalid.1 The Tribunal held that approving 23 draft orders within 24 hours without proper review constitutes a mechanical, non-judicial exercise of power.
ITAT Mumbai quashed search assessments under Section 153C, ruling that a single, non-speaking, and mechanical approval granted under Section 153D for multiple assessment years is invalid.
ITAT upheld CIT(A)’s order deleting additions for AY 2013–14, ruling that year fell outside six-year block under Section 153C based on satisfaction date in FY 2021–22.
