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...
The ITAT held that approval under Section 151 was invalid as the PCIT merely noted As per Annexure without independent satisfaction. The reassessment under Section 147 was declared void ab initio.
The Tribunal noted that the subject line of the approval letter excluded the concerned assessment year, evidencing lack of scrutiny. It held that such defective approval invalidates the assessment.
ITAT ruled that reliance on statements without offering cross-examination and without supporting evidence violates principles of natural justice. Additions under Sections 69A and 153C were set aside.
The Tribunal held that mere booking of flats and receipt of token advances do not justify revenue recognition under the Percentage Completion Method without legally enforceable agreements.
The Tribunal held that once satisfaction is recorded under Section 153C, assessment for covered years must proceed strictly under that provision. Framing assessment under Section 143(3) was declared jurisdictionally invalid and quashed.
The Supreme Court confirmed that reassessment powers under Section 148 cannot be used to bypass the statutory scheme for search cases. The decision clarifies the distinct operating fields of Sections 153C and 148.
The Court held that reassessment based solely on material seized in a third-party search must proceed under Section 153C, not Section 148. Notices issued under the general reassessment provision were set aside.
The Tribunal restored the matter after finding that the appellate authority failed to decide the assessees grounds on merits. The case was remanded for fresh adjudication with directions to consider all documents.
The issue was whether purchases recorded by the assessee were genuine. The Tribunal held that seized Tally data and statements proved bogus purchases, justifying full addition.
ITAT Delhi held that satisfaction note recorded before initiation of the proceedings u/s 153C of the Income Tax Act is not a valid satisfaction. Accordingly, proceedings u/s. 153C of the Income Tax Act is quashed since based on invalid satisfaction.
