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Section 153C

Latest Articles


No Incriminating Evidence, No Addition: Delhi High Court’s Ruling

Income Tax : Delhi HC rules in PCIT Vs Pavitra Realcon Pvt. Ltd., ITA 579/2018, emphasizing the need for corroborative evidence in tax assessme...

July 17, 2024 801 Views 0 comment Print

Possession of Unearthed Material during search Necessary to Invoke Section 153C

Income Tax : Explore the intricacies of invoking Section 153C of the Income Tax Act, as clarified by the Delhi High Court, regarding the posses...

April 22, 2024 594 Views 0 comment Print

Section 153A & 153C of Income Tax Act: Analysis & Implications

Income Tax : Delve into the provisions of Income Tax Act Sections 153A & 153C, governing assessments after search or requisition. Learn from co...

February 8, 2024 6582 Views 0 comment Print

Section 147 to 153 Income Escaping Assessment (Reopening of Cases)

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...

December 10, 2023 19620 Views 7 comments Print

Major changes in ITR for FY 2023-24

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...

August 3, 2023 24177 Views 1 comment Print


Latest Judiciary


Unsigned Excel Sheet Insufficient for Section 153C Proceedings without Corroboration

Income Tax : Gujarat High Court dismisses Revenue’s appeal as unsigned excel sheet lacks corroboration in S. 153C Income Tax Act proceedings....

July 15, 2024 438 Views 0 comment Print

AO Cannot Reopen Assessments U/s. 153A Without Incriminating Evidence: Kerala HC

Income Tax : Read the Kerala High Court judgment on income tax assessments involving Sunny Jacob Jewellers. Analysis includes AO's authority un...

June 26, 2024 333 Views 0 comment Print

Income Tax Addition cannot Be based Solely on unsubstantiated Loose Slips

Income Tax : The ITAT Bangalore ruled that income tax additions can't be based solely on unsubstantiated loose slips, emphasizing the need for ...

June 25, 2024 603 Views 0 comment Print

Delhi HC Invalidates Reassessment Notice, Upholds Section 149(1)(b) Time Limits

Income Tax : Delhi High Court rules that reassessment actions post-2021 searches must meet the First Proviso to Section 149(1) of the Income Ta...

June 14, 2024 1509 Views 0 comment Print

Section 153C Assessments Beyond 10 Years Block Period Invalid: Delhi HC

Income Tax : Delhi High Court rules Section 153C assessments beyond the 10-year limit unsustainable, quashing notices for AY 2013-14. Key judgm...

June 13, 2024 357 Views 0 comment Print


Latest Notifications


Government extends timelines for Income Tax Assessment (Read Notification)

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...

April 27, 2021 68580 Views 4 comments Print

Selection of Case of Search Years in ITBA Assessment module

Income Tax : Availability of Miscellaneous Functionalities related to ‘Selection of Case of Search Year’ and ‘Relevant Search...

September 12, 2019 2094 Views 0 comment Print


Section 153C | CIT (Appeals) must examine issue of recording of satisfaction 

February 8, 2021 522 Views 0 comment Print

R.N. Shetty Trust Vs ACIT (ITAT Bangalore) As per Section 153C of the Act, the Assessing Officer of searched person shall proceed against such other person on reaching satisfaction that any undisclosed income belonging to such other person over whom he has no jurisdiction then he has to transmit the seized material to the Assessing […]

New Procedure for Income escaping & search assessments

February 4, 2021 24201 Views 0 comment Print

Under the Act, the provisions related to income escaping assessment provide that if the Assessing Officer has reason to believe that any income chargeable to tax has escaped assessment for any assessment year, he may assess or reassess or re­compute the total income for such year under section 147 of the Act by issuing a […]

Income Tax Search & Seizure Assessments & Settlement Commission

February 2, 2021 4239 Views 0 comment Print

Finance Bill 2021- Paradigm Shift In The Provisions Relating To Income Tax Search And Seizure Assessments And Income Tax Settlement Commission Introduction:- The Hon’ble Union Finance Minister Nirmala Sitharaman has presented the Union Budget 2021 of India on the 1st of February, 2021. Budget 2021 is aimed at reviving an economy that plunged into deepest […]

Section 153D Approval granted by JCIT without application of mind is invalid

January 19, 2021 3345 Views 0 comment Print

Sanjay Duggal Vs ACIT (ITAT Delhi) ITAT observed that In some of the cases the approval was granted on the date the request was made for approval by the A.O. In all those cases merely draft assessment order and the assessment folders were available with the A.O. For example in the case of Shri Sanjay […]

Absence of satisfaction of AO of searched person must for other person without which jurisdiction assumed under 153C is invalid

January 16, 2021 1065 Views 0 comment Print

Tanvir Collections Pvt. Ltd. Vs ACIT (ITAT Delhi) Absence of satisfaction of AO of searched person must for other person without which jurisdiction assumed under 153C is invalid It is palpable that the AO of Shri B.K. Dhingra, Smt. Poonam Dhingra and M/s Madhusudan Buildcon Pvt. Ltd., did not record any satisfaction that some money, […]

Assessment u/s 153C cannot be made in absence of incriminating documents discovered during search

November 24, 2020 1701 Views 0 comment Print

PCIT Vs S.R.Trust (Madras High Court) Conclusion: In the absence of any incriminating documents or evidence discovered during the course of search under Section 132 in the case of searched person against the assessee, the jurisdiction under the provisions of Section 153C could not be assumed. Held:  Assessee was a charitable trust registered under Section […]

To acquire section 153C Jurisdiction, Documents Seized must be Incriminating

November 16, 2020 2187 Views 0 comment Print

The issue under consideration is whether to acquire jurisdiction under section 153C is it require that the seized documents must be incriminating and must relate to the assessment year whose assessment were sought to be reopened?

Section 147/148 proceedings on mere investigation wing information was not valid

November 12, 2020 11799 Views 0 comment Print

Hitesh Ashok Vaswani Vs DCIT (ITAT Ahmedabad) In the present case the search information received from the investigation wing was used to form the reason to believe by the AO but without applying the mind. Thus the reasons were merely recorded on the borrowed satisfaction by the AO. The source for all the conclusions was […]

Addition for Cash seized during search allegedly belonging to other persons valid if Assessee not furnishes any explanation/Evidence

November 6, 2020 2016 Views 0 comment Print

Where assessee did not produce any material, despite opportunity being afforded to show that the amount seized during the search, did not belong to it but belonged to some other person as claimed by it; the addition made in the hands of the assessee on account of cash seized during the search would be sustainable.

Section 153C notice without recording Satisfaction Note is unjustified

October 31, 2020 9420 Views 0 comment Print

The issue under consideration is whether the issuing notice u/s 153C to the person other than person against whom search is initiated, but without submitting satisfaction note is justified in law?

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