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 why a consolidated satisfaction note for multiple assessment years is legally invalid under Section 153C of the Income Tax A...
Income Tax : Learn about the new block assessment provisions for cases involving searches under section 132 and requisitions under section 132A...
Income Tax : The Bombay High Court invalidated reassessment proceedings because the satisfaction note was recorded with delay and lacked a mand...
Income Tax : ITAT Chennai held that where unaccounted purchases are found and the corresponding sales are not doubted, only the profit element ...
Income Tax : ITAT Bangalore held that the Assessing Officer must establish bogus purchases with cogent evidence before making additions. Since ...
Income Tax : The case addressed whether tax authorities can issue notices for multiple years based on one satisfaction note. The tribunal ruled...
Income Tax : ITAT Delhi held that recording a single satisfaction note for multiple assessment years violates Section 153C requirements. As no ...
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...
The Bombay High Court invalidated reassessment proceedings because the satisfaction note was recorded with delay and lacked a mandatory Document Identification Number.
ITAT Chennai held that where unaccounted purchases are found and the corresponding sales are not doubted, only the profit element embedded in such purchases can be brought to tax, and not the entire purchase value. Accordingly, addition towards unaccounted purchases duly restricted.
ITAT Bangalore held that the Assessing Officer must establish bogus purchases with cogent evidence before making additions. Since the assessee produced complete records and the AO found no defects, the entire addition was deleted.
The case addressed whether tax authorities can issue notices for multiple years based on one satisfaction note. The tribunal ruled that each assessment year requires an independent satisfaction linking seized material.
Judicial rulings clarify that satisfaction for initiating action against other persons in search cases must be recorded promptly. Inordinate delay in recording the satisfaction note can lead to the proceedings being quashed as time-barred.
ITAT Delhi held that recording a single satisfaction note for multiple assessment years violates Section 153C requirements. As no year-specific incriminating material was identified, the assessments were quashed along with the related penalty.
ITAT Ahmedabad held that an unsigned Excel sheet found during survey, without corroborative evidence, cannot justify addition for alleged cash payments.
The High Court held that penalty under Section 271D cannot be levied without the Assessing Officer recording satisfaction regarding violation of Section 269SS. In the absence of such finding in the assessment order, the penalty was set aside.
The Tribunal quashed the reassessment as the notice issued beyond three years failed to satisfy mandatory conditions under Section 149(1)(b). It held that absence of proper jurisdictional facts and compliance rendered the reopening invalid.
Section 69C addition of ₹1.10 crore deleted as pen drive data lacked valid 65B certificate; ITAT Hyderabad held third-party digital evidence inadmissible without corroboration.
