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 held that completed assessments cannot be disturbed under section 153C without incriminating material found during search. Additions based solely on third-party data were ruled invalid.
The issue was whether settled losses could be ignored in a search assessment without incriminating material. The Tribunal held that the AO must start from the last assessed income and allow already determined losses.
Rejecting contradictory treatment, the Tribunal ruled that the Revenue cannot approbate and reprobate by accepting the lender’s scrutiny while taxing the borrower under section 68. The addition was therefore deleted.
The issue was whether Section 153C proceedings for seven years could rest on a single satisfaction note. ITAT held that absence of year-wise satisfaction vitiates jurisdiction, quashing all assessments.
The Tribunal ruled that CIT(A) exceeded jurisdiction by remanding a completed scrutiny assessment. The decision clarifies that remand powers apply only to Section 144 assessments, not regular ones.
The issue was whether a regular assessment could survive once section 153C was triggered for a non-searched person. The Tribunal ruled that pending scrutiny abates, making an assessment under section 143(3) void from inception.
The ITAT held that an unsigned and unexecuted seized agreement cannot establish receipt of cash. The key takeaway is that additions under Section 69A require proof of actual receipt, not mere allegations.
The Tribunal set aside an addition made only on documents seized from a builder during search proceedings. The ruling underscores that independent evidence against the assessee is mandatory.
The issue was whether common and ritualistic approval under section 153D can sustain search assessments. ITAT held that mechanical approval without independent application of mind vitiates the entire proceedings.
The notice under section 143(2) did not conform to the CBDT-prescribed format. ITAT ruled that a defective notice strikes at jurisdiction and invalidates the assessment.
