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...
ITAT Mumbai deleted ₹20,000 yearly penalties where assessments under section 153C accepted returned income with no additions, holding notice non-compliance as merely technical.
The Tribunal considered whether RTGS credits constituted unexplained money. It ruled that once sale bills, customer ledgers, and bank entries align, Section 69A has no application.
The decision reiterates that once the assessees death is known, proceedings must restart with a valid notice to the legal heir. Failure to do so makes the assessment unsustainable.
It was ruled that the date of recording the satisfaction note is the deemed search date for a non-searched person. The ten-year limitation must be counted from this date, not from the original search.
The Tribunal deleted both substantive and protective additions made across multiple years on the same alleged receipts. It held that such duplication results in impermissible multiple taxation of identical amounts.
The issue was whether a search-based assessment could be completed within 12 months after a Supreme Court ruling. The Court held that only the 60-day extended period under section 153B applied, rendering the assessment time-barred.
The Tribunal held that a common, perfunctory sanction under Section 153D is invalid. The key takeaway is that lack of independent application of mind vitiates search assessments entirely.
The Tribunal held that where reassessment is based solely on search material found during a third-party search, proceedings must be initiated under section 153C. Reopening under section 147 was held to be without jurisdiction and quashed.
Reassessment was struck down as no satisfaction note by the searched person’s AO was shown. The ruling reiterates that limitation cannot be bypassed through procedural shortcuts.
The dispute concerned the correct terminal point for computing six assessment years under section 153C. The Tribunal held that using the search date instead of the satisfaction date vitiated the entire assessment.
