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 : CBDT issues new compounding guidelines simplifying process, eligibility, charges, and procedures under the Income-tax Act from Oct...
Income Tax : A summary of prosecution offences under Chapter XXII of the Income Tax Act (Sections 275A to 280), detailing the rigorous imprison...
Income Tax : CBDT's new Compounding of Offence Guidelines (2024) simplify the process but maintain strict compliance rules. Learn about eligibi...
Income Tax : Learn about the new block assessment provisions for cases involving searches under section 132 and requisitions under section 132A...
Income Tax : The case examined whether compensation paid to exit prior agreements was a sham arrangement. The Tribunal ruled it was a valid bus...
Income Tax : The Tribunal held that loan repayment cannot be treated as unexplained cash credit under section 68. The addition was deleted as i...
Income Tax : The issue was whether a notice granting less than the statutory minimum time is valid. The tribunal held that giving less than 7 d...
Income Tax : Reassessment proceedings was invalid for a notice issued beyond three years without the sanction of the prescribed higher authorit...
Income Tax : The Tribunal held that unsigned excel sheets without supporting evidence cannot justify additions. It ruled that absence of corrob...
Income Tax : Availability of Miscellaneous Functionalities related to ‘Selection of Case of Search Year’ and ‘Relevant Search...
Delhi High Court held that since AY 2012-13 falls beyond the block of ten years that are required to be reckoned from the end of the AY 2022-23 assuming jurisdiction u/s. 153C in respect of AY 2012-13 is invalid. Accordingly, appeal of revenue dismissed.
The Delhi High Court quashed a reassessment notice issued to Janus Infrastructure Projects for AY 2014-15, as it exceeded the 10-year limit under Section 149 of the Income Tax Act, as amended in 2021.
ITAT Delhi held that mere confession of accused cannot be a ground for conviction since the same is not supported by credible evidence on records. Accordingly, addition under section 69 of the Income Tax Act deleted.
ACIT Vs Dalmia Cement (Bharat) Limited (Madras High Court) Re-Assessments Possible even after concluded assessment u/s 153A: Madras High Court’s Landmark Ruling in ACIT v. Dalmia Bharat Ltd. Overview: This is a significant tax law case concerning the reopening of income tax assessments beyond the normal limitation period of four years. The Division Bench of the […]
An assessment order passed by AO was quashed on the reason that assessment year was beyond the ten-year outer ceiling limit prescribed by Section 153A. Assessee challenged the assumption of jurisdiction by AO and consequent passing of the Assessment Order. Assessee challenged the issuance of notice u/s 153A for the assessment year 2008-09 on the reasoning that the said notice was issued beyond the period of limitation.
Patna High Court held that reassessment proceedings initiated on the basis of incorrect information which was not supported by any material is not sustainable in law. Accordingly, order passed thereon is liable to be quashed.
ITAT Delhi held that approval memo u/s. 153D of the Income Tax Act is totally silent on the issues involved and has been granted omnibus approval without any thoughtful process being discernible. Thus, assessment order vitiated due to such mechanical approval.
ITAT Mumbai upheld CIT(A)’s rulings in ACIT vs GM Modular Pvt. Ltd., addressing unverified purchases, PF/ESI disallowances, and incriminating material in search cases.
Allahabad HC upheld ITAT’s decision in PCIT vs Sapna Gupta, ruling the Section 153D approval was mechanical, invalidating the assessment proceedings.
Gulshan Investment Pvt. Ltd. Vs JCIT (OSD) (ITAT Delhi) No Addition u/s 153A without incriminating material found during search – Statements of third parties not sufficient: ITAT Delhi Gulshan Investment Pvt. Ltd & others Vs JCIT -ITA No.3872/Del/2024 dt 16.4.25 The core dispute involves additions made by the AO u/s 153A following a search & […]