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...
ITAT Delhi held that addition towards undisclosed overseas bank account was confirmed on wrong notion of denial of appellant to sign consent waiver form. Matter remanded back as appellant has signed the consent waiver form and accordingly AO can carry out relevant enquiry.
ITAT Delhi held that initiation of proceedings u/s 153C of the Income Tax Act based on seized dumb documents found in the premises of third party is unsustainable in law as the seized documents are merely loose sheets not forming part of the books of account of the assessee and that they do not constitute admissible evidence.
ITAT Mumbai held that addition under section 69B of the Income Tax Act towards unexplained investment sustained excel sheet and whatsapp chat are incriminating material found and seized during the course of search action.
ITAT Hyderabad held that law doesn’t permit delegation of authority by PCIT to Assessing Officer (AO) for the purpose of imposition of penalty. Accordingly, direction issued by PCIT to AO to initiate penalty proceedings u/s 271(1)(c) of the Income Tax Act is unlawful.
Ashvin Narayan Bajoria (HUF) Vs ITO (ITAT Surat) Recently the SMC Bench of Surat Income Tax Appellate Tribunal passed a judgement in the aforementioned case deleting the penalty levied by the Ld. Assessing Officer under section 271(1)(c) of the Act for concealment of income. The central point of discussion was whether or not penalty imposed […]
ITAT Jaipur held that in absence of a valid satisfaction note the notice issued under Section 153C of the Income Tax Act 1961 is bad in law. Resultantly the assessment order passed u/s 143(3) r.w.s. 153C of the Act is void ab initio and liable to be quashed.
ITAT Chennai held that in absence of incriminating material as a result of search, no addition can be made in the assessment framed u/s.143(3) r.w.s.153A of the Act, if such assessments are unabated on the date of search.
ITAT Delhi held that once a matter has been considered and decided by the ld.CIT(A), the very same issue cannot be the subject matter of consideration at all by PCIT in the revision proceedings either on substantive basis or on protective basis. Accordingly, revision order quashed.
ITAT Chennai held that in the present case AO himself referred the matter for special audit u/s 142(2A), however, report of special auditor was later rejected without assigning any reasons for the same is in explicable.
This article analyzes how Section 153’s time limit prevails over Section 144C’s assessment time limit, based on the case of Shelf Drilling Ron Tappmeyer Limited Vs ACIT in Bombay High Court.
