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Section 153A

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Compounding of offence under the Income-tax Act, 1961

Income Tax : This document provides a complete reference on compounding of offences, including application procedures, offence-wise charges, re...

June 30, 2026 3585 Views 0 comment Print

FAQs on Compounding of Offences under Income Tax Act, 1961

Income Tax : The FAQs explain the revised CBDT guidelines on compounding offences under the Income-tax Act effective from 17 October 2024. They...

June 22, 2026 2355 Views 0 comment Print

FAQs on Prosecution provision under Income Tax Act, 1961

Income Tax : The FAQs explain the prosecution provisions under the Income-tax Act, covering offences such as tax evasion, non-payment of TDS/TC...

June 20, 2026 7545 Views 0 comment Print

Delay in Recording Satisfaction Note Under Section 153C Can Invalidate Search Proceedings

Income Tax : Judicial rulings clarify that satisfaction for initiating action against other persons in search cases must be recorded promptly. ...

March 11, 2026 2343 Views 0 comment Print

Special vs General: Time Limit Conflict between Section 144C(13) and Section 153 of Income Tax Act, 1961

Income Tax : Courts are divided on whether the DRP-specific deadline under Section 144C(13) overrides the general assessment time bar in Sectio...

December 16, 2025 3135 Views 0 comment Print


Latest News


Budget 2024: Block Assessment provisions for Section 132 & 132A Searches

Income Tax : Learn about the new block assessment provisions for cases involving searches under section 132 and requisitions under section 132A...

July 23, 2024 2469 Views 0 comment Print


Latest Judiciary


Section 153C Assessment Quashed for Defective Consolidated Satisfaction Note: ITAT Delhi

Income Tax : ITAT Delhi quashed a Section 153C assessment, holding that a consolidated and defective satisfaction note invalidated jurisdiction...

July 5, 2026 117 Views 0 comment Print

Sale Deed Alone Cannot Justify Tax Addition as It Is Not Incriminating Material: ITAT Delhi

Income Tax : ITAT held that a registered sale deed without corroborative evidence is not incriminating material and cannot support additions in...

July 4, 2026 291 Views 0 comment Print

Section 148 Reassessment Based on Pre-2021 Third-Party Search Material Invalid; Section 153C Mandatory: ITAT Kolkata

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...

July 4, 2026 162 Views 0 comment Print

Section 148 Notice Issued Beyond First Proviso to Section 149 Time Limit Quashed: ITAT Mumbai

Income Tax : ITAT Mumbai quashed a Section 148 notice issued after the limitation under the first proviso to Section 149, holding the reassessm...

July 4, 2026 339 Views 0 comment Print

ITAT Deletes Section 271D Penalty as AO Failed to Record Satisfaction

Income Tax : ITAT held that penalty under Section 271D cannot survive where the Assessing Officer failed to record satisfaction in the assessme...

July 3, 2026 99 Views 0 comment Print


Latest Notifications


Selection of Case of Search Years in ITBA Assessment module

Income Tax : Availability of Miscellaneous Functionalities related to ‘Selection of Case of Search Year’ and ‘Relevant Search...

September 12, 2019 2565 Views 0 comment Print


Approval accorded u/s. 153D without application of mind is unenforceable in law

May 25, 2023 2310 Views 0 comment Print

ITAT Delhi held that hollow and cosmetic approval accorded under section 153D of the Income Tax Act without application of mind is unenforceable in law and hence liable to be quashed.

Income generated cannot be held bogus only based on modus operandi

May 19, 2023 1869 Views 0 comment Print

ITAT Ahmedabad held that the income generated by the assessee cannot be held bogus only based on the modus operandi. To hold income earned by the assessee as bogus, specific evidence has to be brought on record by the Revenue. In absence of any specific finding, assessee cannot be held to be guilty.

Third party statement recorded u/s 132(4) not an incriminating document for addition u/s 153A

May 17, 2023 8817 Views 0 comment Print

ITAT Hyderabad held that statement of a third party already recorded u/s 132(4) of the Income Tax Act cannot be considered as an incriminating document for the purpose of making the addition u/s 153A of the Income Tax Act.

Notional interest not taxable as bank statement doesn’t show credit of any interest

May 17, 2023 1500 Views 0 comment Print

ITAT Delhi held that notional interest cannot be taxed as income as bank statement of the foreign bank account doesn’t show that any interest has been credited.

Section 153A cannot be invoked if escaped income is not represented “in the form of asset”

May 16, 2023 3021 Views 0 comment Print

AO not shown that alleged income escaped for assessment is represented in the form of an asset. What is assessed in this year u/s 153A of the Act is the addition towards alleged bogus purchases and disallowance of salary/professional fee u/s 37 of the Act.

Assessment u/s 153C beyond six assessment year is without jurisdiction

May 15, 2023 981 Views 0 comment Print

ITAT Mumbai held that the assessment made u/s 153C of the Income Tax Act beyond the six assessment year is without jurisdiction and liable to be quashed.

Assessment order passed is not legal as approval u/s 153D was given in mechanical manner

May 14, 2023 2616 Views 0 comment Print

ITAT Delhi held that assessment order passed under section 153A of the Income Tax Act is not legal and liable to be quashed as approval given under section 153D of the Income Tax Act is granted in a mechanical manner and without application of mind.

No violation of rule 46A as tally accounts produced before CIT(A) provided only better clarity

May 8, 2023 1389 Views 0 comment Print

ITAT Mumbai held that tally accounts produced before CIT(A) provides only better clarity and understanding of seized documents which are already on record before AO. Hence, submission of the same before CIT(A) doesn’t violate provisions of rule 46A of Income Tax Rules.

Addition u/s 69 based on loose papers sustained on failure to contradict facts found during search

May 5, 2023 1329 Views 0 comment Print

ITAT Mumbai held that addition under section 69 of the Income Tax Act on unaccounted, undisclosed income on the basis of the seized loose papers sustained as assessee failed to discharge his onus by contradicting the facts found during search proceedings.

Addition unsustainable as identity and creditworthiness of investor company duly proved

May 4, 2023 1014 Views 0 comment Print

ITAT Raipur held that addition as an unexplained cash credit u/s 68 of the Income Tax Act unsustainable in as much as the assessee company has duly discharged the onus of proving the identity and creditworthiness of the investor company.

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