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 Tribunal held that an unsigned agreement without corroboration cannot be treated as incriminating material. Proceedings under ...
Income Tax : The Tribunal deleted additions where the Revenue failed to prove actual cash transactions. It emphasized that suspicion and assump...
Income Tax : The Tribunal held that reopening under Section 147 was invalid where it was based on third-party search material. It ruled that Se...
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 : The Court held that a 21-month delay in recording the satisfaction note violates the requirement of immediacy. It ruled that such ...
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 issue was whether a search-based assessment could be completed within 12 months after a Supreme Court ruling. The Court held that only the 60-day extended period under section 153B applied, rendering the assessment time-barred.
The Tribunal held that a common, perfunctory sanction under Section 153D is invalid. The key takeaway is that lack of independent application of mind vitiates search assessments entirely.
The Tribunal held that where reassessment is based solely on search material found during a third-party search, proceedings must be initiated under section 153C. Reopening under section 147 was held to be without jurisdiction and quashed.
Reassessment was struck down as no satisfaction note by the searched person’s AO was shown. The ruling reiterates that limitation cannot be bypassed through procedural shortcuts.
The dispute concerned the correct terminal point for computing six assessment years under section 153C. The Tribunal held that using the search date instead of the satisfaction date vitiated the entire assessment.
Holding the assessment void ab initio due to limitation, the Tribunal quashed the revision orders. The ruling underscores that revision cannot cure a fundamentally invalid assessment.
The Tribunal clarified that approval under section 153D is an administrative safeguard and need not contain elaborate reasoning. Allegations of mechanical approval fail without concrete evidence of non-application of mind.
The tribunal held that assessment under section 153C cannot be initiated without seized material belonging to or relating to the assessee. Third-party statements and assumptions, without incriminating evidence, were held insufficient to confer jurisdiction
The Tribunal held that additions in a search assessment cannot survive without incriminating material. Mere repetition of an annulled earlier assessment was found legally unsustainable.
It was ruled that once books are accepted, expenses supported by ledgers, vouchers, and bank payments cannot be disallowed on suspicion. Ad-hoc estimation without rejecting books was held invalid.
