Income Tax : Delhi HC rules in PCIT Vs Pavitra Realcon Pvt. Ltd., ITA 579/2018, emphasizing the need for corroborative evidence in tax assessme...
Income Tax : Explore the intricacies of invoking Section 153C of the Income Tax Act, as clarified by the Delhi High Court, regarding the posses...
Income Tax : Delve into the provisions of Income Tax Act Sections 153A & 153C, governing assessments after search or requisition. Learn from co...
Income Tax : Learn about Section 147 to 153 Income Escaping Assessment and Reopening of Cases Under Income Tax Act, 1961. Get guidance on the p...
CA, CS, CMA : Discover the major changes in ITR forms for FY 2023-24 (AY 2024-2025). Highlights include new sections for retirement benefit acco...
Income Tax : Learn about the new block assessment provisions for cases involving searches under section 132 and requisitions under section 132A...
Income Tax : ITAT Pune remands the case of Suhas Maruti Dhankude for re-adjudication due to non-adjudication of jurisdictional grounds and fail...
Income Tax : Notice under section 148 was issued upon assessee by AO for reassessing the cash deposit as undisclosed income, following approval...
Income Tax : Delhi High Court held that in case of search, block period of ten years for search assessment, would not be attracted in case the ...
Income Tax : ITAT Delhi held that in respect of assessment proceedings u/s. 153C of the Income Tax Act, block period of six assessment years ha...
Income Tax : Gujarat High Court dismisses Revenue’s appeal as unsigned excel sheet lacks corroboration in S. 153C Income Tax Act proceedings....
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...
Palla Simhachalam (HUF) Vs ACIT (ITAT Visakhapatnam) AO of the searched person and the other person is one and the same, then also AO is required to record the satisfaction, as held by the various In the instant case, no such material has been brought before us by the ld. DR. In view of the […]
If no incriminating material found during Income Tax search in respect of an issue, no addition for such issue can be made Sections 153A/153C
Held that the period of limitation prescribed under Section 153 (2A) or 153 (3) is applicable, when the matters are remanded back irrespective of whether it is to the Assessing Officer or TPO or the DRP, the duty is on the assessing officer to pass orders.
Pradeep Kumar Varshney Vs ITO (Delhi High Court) Learned counsel for the Petitioner states that in the present case notice under Section 148A is not warranted as it is a case of Section 153C of the Act to which proviso (c) of Section 148A applies. In response to a pointed query, Mr. Sunil Agarwal, learned […]
rticle discusses about Appealable orders in case of appeal by the taxpayer, Appealable orders in case of appeal by the Commissioner, Appeal not to be filed by the department in certain cases, Time- limit for presenting appeal, Form and signature, Memorandum of cross objection, Documents to be submitted with appeal, Fees for filing the appeal, Fees for filing the appeal in other cases,
We hold that in absence of any incriminating material found during the course of search with respect to the impugned transaction, the AO did not have any power to make the impugned addition.
It is well settled proposition of law that the apprehension, howsoever strong, cannot substitute material evidences. A.O. was not justified in treating part of liabilities as unproved on presumptions, surmises and conjectures
K.S. Nutrition and Food Pvt. Ltd. Vs ITO (ITAT Delhi) Assessee, inter alia, submitted that the Assessing Officer was not justified in assuming jurisdiction u/s. 153C of the Act in the present case, as the assessment year under consideration does not come within the compass of the block of six assessment years, if it is […]
Neesa Technologies Pvt. Ltd. Vs DCIT (ITAT Ahmedabad) Since the proceedings u/s. 153C of the Act were initiated in the present case on the basis of documents which we have held above neither belonged to the assessee nor were incriminating in nature, they were not sufficient for assuming jurisdiction u/s. 153C of the Act. The […]
The pertinent assertion of learned counsel Shri Gargieya is that the assessing authority could not have adopted the procedure provided under Section 148 of the Income Tax Act for reopening the assessment of the petitioner because such action was taken on the basis of facts revealed to the assessing authority during the assessment of DRA Group at Ahmedabad and the proceedings, if any, would have to be conducted under Section 153A read with Section 153C of the Income Tax Act.