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 ruled that the reassessment was time-barred because limitation was wrongly computed from the search date. The key takeaway is that receipt of seized material governs jurisdiction for non-searched persons.
Gattula Lakshmi Madhavi Vs ACIT (ITAT Visakhapatnam) Central Circle Cannot Assume Reassessment Powers — Section 148 Notice Issued Outside Faceless Regime Held Void The Visakhapatnam Bench of the ITAT quashed the reassessment framed under Section 147 and consequential penalties under Sections 270A and 271AAC in the case of Gattula Lakshmi Madhavi v. ACIT, holding that […]
Madras High Court held that Settlement Commission doesn’t possess power to change the head of income and convert the undisclosed portion of income into income u/s. 699B. Further, Settlement application is bound to be rejected once Settlement Commission arrives at the conclusion that full and true disclosure is not done.
The issue was whether revision under section 263 could survive when no incriminating material was found for an unabated year. The tribunal held that without search-based evidence, the completed assessment could not be disturbed.
The assessing officer estimated commission income by assuming investments were accommodation entries. The tribunal confirmed that additions based on assumptions, without concrete evidence, are legally unsustainable.
The issue was whether cash found at a third party’s premises could be added in the assessee’s 153A assessment. The Tribunal held such additions invalid, ruling that proceedings must be initiated under section 153C.
The Tribunal ruled that additions for alleged cash payments cannot survive when based solely on third-party statements and unverified electronic data. Absence of corroboration and denial of cross-examination violated principles of natural justice.
The Tribunal clarified that revisionary jurisdiction presupposes a valid assessment order. Where Section 153C itself is time-barred, Section 263 has no application.
The Tribunal held that revision under Section 263 cannot be exercised over a search assessment completed under Section 153C with proper approval under Section 153D. Unless such approval is shown to be erroneous, revisional jurisdiction does not arise.
Revenue issued 153C notices for years far preceding the satisfaction date. Following binding judicial precedent, the tribunal ruled that such assessments were beyond the ten-year statutory window and could not survive.
