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 Section 2(22)(e) cannot apply where the assessee held less than 10% shareholding in the lending company. As statutory thresholds were not met, the deemed dividend addition was largely deleted.
Applying Supreme Court precedent, the Tribunal held that no notice could be issued once the six-year period under the old regime had expired. The reassessment order was therefore annulled.
The Court held that notice under Section 148A(b) was valid despite search-related arguments. However, the assessment was set aside due to absence of proper reasoning on denial of Section 10(38) exemption for long-term capital gains.
The Court held that reassessment based solely on material seized in a third-party search must proceed under Section 153C, not Section 148. Notices issued under the general reassessment provision were set aside.
A single approval was granted for multiple years without examining seized material or draft orders. The Tribunal ruled that such omnibus approval vitiates proceedings under Sections 153A/143(3).
The Tribunal held that reopening AY 2012–13 after a post-2021 search was barred by limitation. Applying Supreme Court guidance, it ruled that older limitation periods protect concluded assessments from retrospective reopening.
Since the reassessment notice was barred by limitation, the tribunal did not examine capital gains issues on merits. The ruling confirms that jurisdictional defects override substantive tax disputes.
ITAT Bangalore held that once the genuineness of the building construction expenditure is proved, the consequential claim of depreciation on such genuine assets cannot be denied to trust since depreciation was claimed only on actual assets used for charitable purpose.
The tribunal held that amounts already disclosed and taxed as accommodated receipts cannot be taxed again under another head. Separate additions were deleted as they resulted in impermissible double taxation.
The ITAT ruled that unexplained cash can only be assessed in the year in which it is seized. An addition made in an incorrect assessment year is legally unsustainable and must be deleted.
