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 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 : ITAT Mumbai deletes Section 69 additions holding that third-party excel sheets and statements without corroborative evidence lack ...
Income Tax : Availability of Miscellaneous Functionalities related to ‘Selection of Case of Search Year’ and ‘Relevant Search...
ITAT Mumbai quashed 143(3) order post-search, deleted ₹96.77L suppressed sales addition, allowed Sec 37(1) expenses & CWIP write-off as revenue in 153A assessment.
The Tribunal held that in completed assessments, no addition can be made under Section 153A without incriminating material found during search. The addition under Section 68 was annulled as jurisdiction was invalid.
ITAT Mumbai held temporary alternate flat under development deal is not a “transfer” u/s 2(47); notarised agreement gave no ownership, so ₹13.56 lakh addition deleted.
ITAT Bangalore quashed reassessment for AY 2017-18, holding notice issued on 12-04-2024 time-barred under first proviso to Sec.149(1), despite prior 148A proceedings.
The Tribunal held that reassessment under Sections 147/148 is invalid when the assessment year is the year of search. Such cases must proceed under normal assessment provisions.
The Tribunal emphasized that assumptions based on common names cannot justify major tax additions. Without documentary linkage or banking trail confirmation, the Revenue’s case could not stand.
Penalty imposed under Section 271AAA was set aside, holding that only the Assessing Officer is empowered to levy such penalty. The Tribunal further ruled that once quantum addition is deleted, penalty cannot survive.
ITAT held that the Assessing Officer failed to record proper satisfaction linking seized material to the assessee’s income. Consequently, proceedings under Section 153C were quashed.
ITAT held that additions relying merely on investigation wing reports and retracted statements, without direct incriminating evidence, violate settled principles governing Section 153A proceedings.
The Tribunal ruled that undated, unsigned loose sheets lacking independent evidence cannot justify additions under Section 153A. Relying on Supreme Court precedent, it deleted additions exceeding ₹2.10 crore for want of corroboration.
