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 Tribunal ruled that a Section 153C notice issued beyond the statutory ten-year period could not survive in law. The assessment order passed pursuant to such notice was therefore annulled as time-barred.
The Bangalore ITAT held that uncorroborated WhatsApp chats and retracted statements are insufficient to sustain large on-money additions in search assessments. Additions based purely on estimates without incriminating evidence were deleted.
ITAT Hyderabad held that the reassessment notice issued for AY 2015-16 after 31.03.2022 was barred by limitation under the first proviso to Section 149 and therefore invalid.
The Tribunal deleted penalty levied on society charges and depreciation disallowances after finding that the claims were fully disclosed in books and audited financial statements. It held that ad hoc disallowances alone cannot trigger concealment penalty.
ITAT Hyderabad held that constituent members of a JV or Consortium can claim deduction under Section 80IA(4) when they actually execute infrastructure projects and bear the associated risks. The Tribunal ruled that the JV structure formed only for bidding does not defeat eligibility.
ITAT Delhi held that the assessee was covered under the search proceedings even though its name did not specifically appear in the panchnama because the warrant referred to “& Ors.” The Tribunal therefore upheld jurisdiction under Section 153A.
The ITAT Delhi upheld deletion of a Rs.6 crore addition under Section 68 after finding that the share sale transactions were properly documented and routed through banking channels. The Tribunal held that the Assessing Officer failed to prove that the transactions represented unaccounted income.
Delhi ITAT held that a single consolidated satisfaction note covering multiple assessment years without identifying year-wise incriminating material is invalid under Section 153C. The Tribunal consequently quashed all related assessments.
The Tribunal ruled that the Assessing Officer wrongly invoked Section 143(3) despite the case being covered under the block assessment provisions of Section 153C. ITAT reaffirmed that jurisdictional defects cannot be cured by regular scrutiny proceedings.
The Tribunal ruled that recording satisfaction under Section 153C is not a mechanical exercise and must clearly establish the relevance of seized material to the assessee’s income.
