Income Tax : The FAQs explain the revised CBDT guidelines on compounding offences under the Income-tax Act effective from 17 October 2024. They...
Income Tax : The article explains who can file appeals before the Income Tax Appellate Tribunal, the orders that are appealable, applicable tim...
Income Tax : The Tribunal held that additions cannot stand without a clear link between seized material and the assessee. It ruled that third-p...
Income Tax : Judicial rulings clarify that satisfaction for initiating action against other persons in search cases must be recorded promptly. ...
Income Tax : CBDT's new Compounding of Offence Guidelines (2024) simplify the process but maintain strict compliance rules. Learn about eligibi...
Income Tax : Learn about the new block assessment provisions for cases involving searches under section 132 and requisitions under section 132A...
Income Tax : Gujarat High Court held that rejection of a Vivad se Vishwas declaration was invalid because final assessment arose from survey pr...
Income Tax : The Tribunal held that an addition under Section 69 could not be sustained solely on the basis of a seized loose sheet without ind...
Income Tax : The ITAT held that assessments under Section 153A were invalid because no search warrant was issued in the assessee’s name. As t...
Income Tax : The ITAT Hyderabad held that the assessment orders were time-barred under Section 153 despite the DRP process. Both assessments we...
Income Tax : The ITAT held that limitation under Section 153B had to be computed from the searched person's last panchanama, making the assessm...
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...
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.
The Tribunal clarified that mere search under Section 132 does not automatically justify reopening. The AO must demonstrate year-specific escapement of income and follow mandatory approval procedures.
The Delhi High Court held that notices issued after the satisfaction note date were time-barred. Following earlier precedent, the impugned notices were set aside.
