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Income Tax : Learn about prosecution under IT Act sections 275A to 280, including penalties and conditions for launching prosecution....
Income Tax : Learn about the compounding of offences under direct tax laws, including eligible offences, competent authorities, and the process...
Income Tax : Learn about the new block assessment provisions for cases involving searches under section 132 and requisitions under section 132A...
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Shri Govind G. Sarawagi HUF Vs. ACIT (ITAT Ahmedabad)- Name of the HUF, who is separate taxable entity, is no where available in the Panchnama. It is also pertinent to note that all the members of the HUF were not covered under the search action.
a person other than the person referred to in section 153A, then, the books of account or documents or assets, seized or requisitioned shall be handed over to the Assessing Officer having jurisdiction over such other person ] and that Assessing Officer shall proceed against
Pepsico India Holdings Private Ltd vs. ACIT (Delhi High Court)-Possession of documents and possession of photocopies of documents are two separate things. While the Jai puria Group may be the owner of the photocopies of the documents it is quite possible that the originals may be owned by some other person.
ITAT Pune held in Mrs Sarita Manjeet Singh Chopra Vs ITO that if the assesse had disclosed its unaccounted income filing return u/s 153A only after it was caught in search by the income tax department then that disclosed income through return would be considered as undisclosed income
ACIT Vs. S.P.Cold Storage (ITAT Raipur)- Mere mentioning of name in Search Warrant & Panchanama not sufficient for contemplating search against the assessee firm, Search at the residential premises of the Partners could not be deemed to be a search on the assessee firm
The ld. Authorised Representative for assessee submitted that the Commissioner of Income Tax (Appeals) erred in not noting that the impugned assessment had been passed in the absence of proper and valid authorization.
In an appeal no.523/2013, the assessee was engaged in the operation of a Container Freight Station (CFS). It filed a return of income on 08.10.2008 declaring total income at Rs. Nil after claiming deduction of Rs.210713675/- u/s 80IA(4) of the Income Tax Act,1961
In the case of Ms. Meena Rani Vs. ACIT, It was held by ITAT Delhi that If no satisfaction note has been recorded in the records of the searched persons but in the records of the assessee, assessment cannot be done U/s 153C
CIT Vs. Mechmen (Madhya Pradesh High Court) In this case court observed that satisfaction was not recorded by the AO before issuing notice u/s 153C which is a fact decided by ITAT. No paper or document was seized against the assessee in the search operation.
Lower authorities have overlooked the principle that the opening balance cannot be disturbed this year. The authorities can only reopen for the earlier year. In another case ACIT Vs. Smt. N. Sasikala (2005) 92 TTJ (Chennai) 119 it was held that If the Department doubted the availability of cash balance, it can go to the concerned assessment year 1990-91
