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...
The Court held that while the assessees reply period had to be excluded under Section 149, the Assessing Officer still failed to issue the Section 148 notice within the extended statutory timeline. The reassessment notice was therefore quashed as time-barred.
The Tribunal ruled that no addition could be sustained where the tax department failed to establish actual receipt of interest income. The key takeaway is that presumptions and notings in seized documents cannot substitute proof of income.
The Tribunal held that AY 2010-11 was outside the permissible ten-year assessment block computable under Section 153A. Applying the Delhi High Court’s interpretation in Ojjus Medicare, it found the notice itself invalid. As a result, the assessment proceedings were quashed and the appeals were allowed.
Assessments arising from searches conducted after 01.04.2021 must strictly comply with the reassessment framework under sections 147 and 148. Failure to adhere to statutory jurisdictional requirements, including mandatory approvals and satisfaction for use of third-party material, rendered the entire assessment void.
The case involved additions for alleged on-money in Godhavi land transactions based on a handwritten loose sheet. The Tribunal restored the matter for fresh consideration, highlighting issues relating to evidence and assessment findings.
The Tribunal held that documents relating to the assessee were found during the search of another person. It ruled that proceedings could only be initiated under Section 153C, making the reassessment under Section 148 invalid.
ITAT Delhi held that reassessment proceedings beyond six years under Section 153C are permissible only where escaped income represented in the form of assets exceeds or is likely to exceed Rs. 50 lakh. Since this statutory condition was not satisfied, the assessments were annulled as time-barred.
ITAT Delhi held that reassessment proceedings beyond the prescribed period were invalid where alleged escaped income arose from unaccounted sales and not from assets. The Tribunal ruled that conditions under Sections 149 and 153A were not satisfied, leading to quashing of multiple reassessment notices.
ITAT held that loose sheets showing cash and cheque transactions could not justify additions under Section 153A where related cheque transactions were accepted as genuine and linked to group business dealings.
Bangalore ITAT held that unsigned loose sheets, scribblings, and rough jottings without corroborative evidence cannot form the sole basis for tax additions. The Tribunal deleted the protective additions linked to alleged capitation fee receipts.
