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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 3582 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 336 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


Dispute on amount of interest Granted by HC – HC ask dept to submit application for review/modification

July 12, 2022 420 Views 0 comment Print

Sanjeevkumar S/o Biharilal Kabra Vs Union of India (Bombay High Court) 1. The matter is placed on board for speaking to minutes in respect of order dated 22.04.2022 passed by this Court. 2. The learned counsel for the petitioners seeks clarification of the order, more particularly in so far as directions issued in paragraph no.43 […]

Carry forward of capital loss, claimed via return filed u/s 153A, is unsustainable

June 28, 2022 990 Views 0 comment Print

Short term capital loss not claimed while filing return u/s 139(1). Loss was claimed for the first time via return u/s 153A. Claim denied according to provisions of section 80.

Penalty not survive if Assessment Order held to be void ab initio

June 24, 2022 1269 Views 0 comment Print

ACIT Vs Rameshbhai Jivrajbhai Desai (ITAT Ahmedabad) During the course of assessment proceedings, the Assessing Officer initiated penalty proceedings under Section 271(1)(c) of the Act. The Ld. AR submitted that the assessment order passed under Section 153A of the Act was held to be void ab initio and thus there is no addition in the […]

Document related to to expenses/EBIDTA details, etc. can’t be said incriminating material to initiate proceedings u/s 153A

June 23, 2022 531 Views 0 comment Print

Vivimed Labs Limited Vs ACIT (ITAT Hyderabad) hon’ble apex court’s landmark decision in CIT Vs. Sinhaghad Technical Educational Society (2017) 84 com 290 (SC) that no such proceedings initiated u/s 153A of the Act sustainable in law for want of incriminating material found or seized during the course of search. We make it clear that […]

Section 153C: Addition for Share Capital without Incriminating Material not sustainable

June 22, 2022 1608 Views 0 comment Print

DCIT Vs Apple Metal Industries Pvt Ltd (ITAT Delhi) Assessment for Assessment Year 2011-12 was completed after making addition on account of unverified share application money amounting to Rs. 8,70,71,936/- and in Assessment Year 2014-15, addition on account of unverified share capital amounting to Rs. 30,00,600/- was made. The impugned assessment order clearly shows that […]

Non Filing of Income Tax Return- Court can presume culpable mental state of accused

June 2, 2022 2091 Views 0 comment Print

Section 278 (e) of the Income Tax Act, 1961, empowers the Court to presume culpable mental state of the accused, unless, the accused shows that he had no such mental state with respect to the act charged as an offence in the prosecution.

Section 153A Assessment cannot be arbitrary & must have nexus with seized material

May 8, 2022 3402 Views 0 comment Print

PCIT Vs LKG Builders P. Ltd. (Delhi High Court) Court is of the opinion that the questions of law raised in present appeals have been settled by earlier Division Bench in CIT Vs. Kabul Chawla (supra) and assessment of the respondents had attained finality prior to the date of search and no incriminating documents or […]

If no incriminating material found during Search- Section 68 additions not sustainable

April 7, 2022 2019 Views 0 comment Print

Since no incriminating material was found during the course of search, as regards the additions made u/s.68 of the Income Tax Act, therefore, no additions could be made.

Issuance of Section 143(2) notice mandatory in Section 153A proceedings

April 3, 2022 2859 Views 0 comment Print

ACIT Vs Dr. P. S. Prasad (ITAT Hyderabad) Learned CIT-DR vehemently reiterated the Revenue’s foregoing pleadings that the issuance of Section 143(2) notice is nowhere mandatory in Section 153A proceedings initiated in furtherance to a search in light of the various case law cited therein. We find no merit in the Revenue’s instant grievance since […]

No addition based on evidence which is not confronted to the assessee

March 28, 2022 7575 Views 0 comment Print

DCIT Vs Rashmi Float Glass Ltd. (ITAT Kolkata) We find that the only addition made is of share application received u/s 68 of the Act and addition of commission paid allegedly for the share application money and finally a disallowance u/s 14A of the Act. No incriminating material has been found during the course of […]

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