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...
Where income admitted in section 153C proceedings is accepted in assessment, penalty still requires strict compliance with section 270A. Absence of a specific misreporting charge defeats penalty levy.
The Tribunal held that reassessment under section 147 fails when seized search material exists. The correct and exclusive route is section 153C, making the reopening jurisdictionally invalid.
The Tribunal held that an assessment under section 153C cannot go beyond the material specified in the satisfaction note. Since additions were based on different material, the entire assessment was quashed.
The Tribunal held that after the High Court invalidated section 153C proceedings, all subsequent tax adjustments including those involving ₹6.68 crore are unsustainable. Judicial finality bars further action.
The Tribunal dismissed the Revenue’s appeal, holding that JDA-related income issues had already attained finality. Any attempt to reassess the same income in an earlier year would result in impermissible double taxation.
The Tribunal held that reassessment initiated after three years was void because approval was taken from an incompetent authority. The key takeaway is strict compliance with section 151(ii) is mandatory and jurisdictional.
The Tribunal held that it was unclear whether the ₹20 lakh receipt was a loan or a property advance and remanded the matter for fresh examination. The ruling underscores that section 68 additions depend on establishing the true character of the receipt through contemporaneous evidence.
The Revenue relied on alleged ₹4 crore unexplained investment to justify reopening beyond six years. The Tribunal ruled that even high-value allegations cannot override statutory limitation under section 153C.
The Tribunal quashed reassessment proceedings where the section 148 notice and section 148A(d) order were issued by the JAO instead of the FAO. It reaffirmed that post-notification violations of the faceless scheme cannot be cured by participation or waiver.
ITAT held reassessment invalid as it was initiated merely on Insight Portal data and third-party statements without verification or application of mind.
