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 case addressed the legality of assessments framed pursuant to a search when the satisfaction note lacked statutory particulars. The Tribunal quashed all assessments, holding them non-est in law due to invalid satisfaction.
The tribunal held that reassessment under Section 153C cannot stand without valid satisfaction as mandated by law. Failure to examine this jurisdictional issue vitiates the proceedings.
The Tribunal held that when reassessment is based on material found during a third-party search, proceedings must be initiated under Section 153C and not Section 147. Reopening under Section 147 was therefore without jurisdiction and liable to be quashed.
Authorities added ₹8 crore as unexplained investment in the wrong year. The Tribunal confirmed that the cash component belonged to a prior year. The ruling stresses year-specific taxation of undisclosed transactions.
The case examined whether entire purchases could be treated as bogus when sales were undisputed. The Tribunal restricted the addition to 6%, holding that only a reasonable estimation was warranted.
The Tribunal clarified that expenditure disallowances do not qualify as assets under section 149(1). Without asset-based escaped income, reopening beyond three years is barred. This offers strong protection against belated reassessments.
The Tribunal held that an assessment framed without issuing a compulsory notice under section 153C lacks jurisdiction. Even seized material cannot cure this foundational defect, rendering the order void ab initio.
ITAT Delhi ruled that granting a common approval for several assessment years violates statutory safeguards. Search assessments collapse if approval is mechanical or omnibus in nature.
Tribunal held that TDS liability under section 194-IA cannot arise unless Revenue proves that payment was actually made. Mere third-party statements were found insufficient to treat buyer as an assessee in default.
The decision reiterates that section 150 is subject to section 150(2) and cannot revive time-barred or jurisdictionally invalid assessments. Directions to reopen were struck down as unlawful.
