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 ITAT held that reassessment notices issued by a JAO after 29.03.2022 are void, as only a Faceless Assessing Officer can act under the faceless regime.
The ITAT ruled that reassessment under section 153C cannot extend beyond the statutory six assessment years. Jurisdiction assumed outside this period was held void.
The Tribunal reaffirmed that satisfaction must be recorded contemporaneously or immediately after the searched person’s assessment. Any belated recording invalidates the assumption of jurisdiction under section 153C.
The Tribunal ruled that cessation must be evidenced by a write-back or clear act in the books. Inferences or time lapse alone cannot trigger section 41(1).
Mumbai ITAT upholds deletion of ₹70 lakh under Section 69, ruling that uncorroborated WhatsApp scribbles from a third party cannot establish unexplained cash income.
The issue was whether unsecured loan additions under section 68 could survive based solely on investigation reports and third-party statements. ITAT held that without independent enquiry and nexus to seized material, such additions are unsustainable.
The Tribunal reaffirmed that revision is impermissible when the Assessing Officer adopts a reasonable view after due enquiry. Section 263 cannot be invoked merely because the PCIT prefers another line of investigation.
The Tribunal deleted on-money additions where the tax department failed to establish a clear nexus between the assessee and alleged cash entries. Suspicion or unverified third-party material was held insufficient in law.
The Court held that reassessment notices failed because seized documents did not relate to the relevant assessment years. Jurisdiction under Section 153C was therefore not validly assumed.
The Tribunal held that additions based solely on third-party statements and Excel data seized from another person cannot survive without independent corroboration. Denial of effective cross-examination rendered the section 69C addition unsustainable.
