Income Tax : The Tribunal held that additions cannot stand without a clear link between seized material and the assessee. It ruled that third-p...
Income Tax : Judicial rulings clarify that satisfaction for initiating action against other persons in search cases must be recorded promptly. ...
Income Tax : CBDT issues new compounding guidelines simplifying process, eligibility, charges, and procedures under the Income-tax Act from Oct...
Income Tax : CBDT's new Compounding of Offence Guidelines (2024) simplify the process but maintain strict compliance rules. Learn about eligibi...
Income Tax : AY 2015-16 assessment under Section 153C held time-barred. Judicial rulings confirm six-year limit runs from handing over of seize...
Income Tax : Learn about the new block assessment provisions for cases involving searches under section 132 and requisitions under section 132A...
Income Tax : ITAT Ahmedabad held that reassessment based solely on search material seized from a third party must be initiated under Section 15...
Income Tax : Mumbai ITAT held that unsecured loans received through banking channels and fully recorded in books cannot be treated as unexplain...
Income Tax : Delhi ITAT held that additions under Section 68 cannot be sustained merely on Investigation Wing reports without independent enqui...
Income Tax : Delhi ITAT held that a single consolidated satisfaction note covering multiple assessment years without identifying year-wise incr...
Income Tax : The Tribunal ruled that the Assessing Officer wrongly invoked Section 143(3) despite the case being covered under the block assess...
Income Tax : Central Government has decided to extend the time limits to 30th June, 2021 in the following cases where the time limit was earlie...
Income Tax : Availability of Miscellaneous Functionalities related to ‘Selection of Case of Search Year’ and ‘Relevant Search...
ITAT Ahmedabad held that reassessment based solely on search material seized from a third party must be initiated under Section 153C and not Sections 147/148. The Tribunal quashed the reassessment for lack of jurisdiction and absence of a mandatory satisfaction note.
Mumbai ITAT held that unsecured loans received through banking channels and fully recorded in books cannot be treated as unexplained money under Section 69A merely on suspicion. The addition and consequential interest disallowance were deleted in full.
Delhi ITAT held that additions under Section 68 cannot be sustained merely on Investigation Wing reports without independent enquiry by the Assessing Officer. The Tribunal deleted additions relating to alleged bogus share capital.
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.
The Hyderabad ITAT held that only the actual period lost during the limitation period can be excluded under Explanation-1 to Section 153. It ruled that the assessment order passed beyond the permissible period was invalid.
The Tribunal ruled that the Revenue must establish a direct connection between seized material and the assessee’s taxable income before invoking Section 153C. Mechanical initiation of proceedings for multiple years was declared invalid.
Hyderabad ITAT held that a notice issued under Section 148 after six years from the end of AY 2015-16 was invalid. The Tribunal ruled that the amended 10-year reopening provision cannot revive already time-barred cases.
ITAT Delhi held that penalty under Section 271AAC cannot survive once the underlying Section 153C assessment is quashed. The Tribunal deleted the penalty after noting that the quantum assessment itself no longer existed.
