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 Tribunal examined whether a single satisfaction note could sustain reassessment proceedings for multiple years under section 153C. It held that a composite satisfaction is valid when based on common seized material spanning several assessment years.
ITAT Delhi held that disallowance of bad debts claimed as deduction under section 36(1)(vii) is not justifiable if offered as income in any year. Accordingly, AO directed to verify that amount for which bad debts have claimed u/s 36(1)(vii) were indeed offered as income for the said years.
The reassessment was struck down because it relied exclusively on third-party search material. The ruling clarifies that section 153C, not section 147, must be invoked where incriminating evidence emerges from another persons search.
The Tribunal held that a protective addition cannot be termed erroneous when the same income has already been assessed substantively in another case. The twin conditions of error and prejudice under section 263 were not satisfied.
ITAT held that Section 153C proceedings were invalid as the relevant years fell beyond the six-year window. Time limitation goes to jurisdiction and cannot be cured later.
The Tribunal held that assessments beyond the permissible six-year block under section 153C are invalid. Proceedings were quashed as the relevant years fell outside the statutory limitation.
The issue was whether a post-search assessment could be completed under section 143(3) using third-party material. The Tribunal ruled that the special reassessment route under sections 148 and 148B was mandatory.
The Tribunal held that reassessment beyond three years is invalid where the alleged escaped income is below ₹50 lakh. A notice issued for a ₹5 lakh donation was declared void ab initio.
The Tribunal held that estimating business income at 10% of turnover without citing comparable cases or industry benchmarks is unsustainable. Arbitrary profit estimation must be supported by material evidence.
The Tribunal examined whether a single, consolidated satisfaction note for multiple assessment years meets the requirement of Section 153C. It held that such consolidated recording vitiates jurisdiction, rendering the search assessments void.
