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...
It was ruled that interest for late filing of the original return can be computed based on tax determined in search-related assessment. Timely filing after notice does not negate earlier delay.
The Tribunal held that estimating commission income without corroborative evidence is unsustainable. Audited accounts and consistent interest income showed genuine business activity, leading to deletion of the addition.
ITAT held that penalties under sections 271D and 271E cannot survive once the underlying additions are deleted. The ruling confirms that penalties collapse with the quantum.
The ITAT held that assessments framed beyond the permissible ten-year block under Section 153C are without jurisdiction. Since the satisfaction note fixed the deemed search year later, earlier years were invalidly assessed.
The Tribunal held that a loan repaid through banking channels cannot be treated as unexplained when identity and creditworthiness are shown. Allegations based on untested statements were rejected.
The Tribunal held that sanction for reopening was granted mechanically and without independent application of mind, as required under Section 151. An undated and non-speaking approval vitiated the entire reassessment proceedings.
The Tribunal held that extended block assessment beyond six years is invalid where escaped income is below ₹50 lakh. Jurisdiction under Sections 153A/153C cannot be assumed without meeting statutory limits.
ITAT affirmed that assessments for block period years must be framed only under Section 153C. Any assessment completed under Section 143(3) during such period is void in law.
The penalty was quashed as the Assessing Officer failed to strike off the inapplicable limb in the notice. Clear satisfaction and precise charge are mandatory for sustaining penalty proceedings.
The Tribunal held that assessments under Section 153A cannot be sustained when no incriminating material is found at the assessees premises. Additions based on third-party material were quashed as being without jurisdiction.
