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 : Budget 2025 revises block assessment rules for search cases, covering undisclosed income, assessment procedures, penalties, and ti...
Income Tax : Learn about the new block assessment provisions for cases involving searches under section 132 and requisitions under section 132A...
Income Tax : Revenue failed to produce a Section 153C satisfaction note showing the date of handing over seized material. ITAT treated the noti...
Income Tax : The issue was whether an assessment could survive when statutory notices were issued in the name of a deceased person. The Tribuna...
Income Tax : ITAT Delhi held that for an unabated year, additions under section 153A require incriminating material. A seized loose sheet and r...
Income Tax : The tribunal ruled that statements of third parties cannot be relied upon unless the assessee is provided copies and allowed cross...
Income Tax : ITAT Mumbai deleted ₹20,000 yearly penalties where assessments under section 153C accepted returned income with no additions, ho...
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 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.
Holding the assessment void ab initio due to limitation, the Tribunal quashed the revision orders. The ruling underscores that revision cannot cure a fundamentally invalid assessment.
The Tribunal clarified that approval under section 153D is an administrative safeguard and need not contain elaborate reasoning. Allegations of mechanical approval fail without concrete evidence of non-application of mind.
The tribunal held that assessment under section 153C cannot be initiated without seized material belonging to or relating to the assessee. Third-party statements and assumptions, without incriminating evidence, were held insufficient to confer jurisdiction
The Tribunal held that additions in a search assessment cannot survive without incriminating material. Mere repetition of an annulled earlier assessment was found legally unsustainable.
It was ruled that once books are accepted, expenses supported by ledgers, vouchers, and bank payments cannot be disallowed on suspicion. Ad-hoc estimation without rejecting books was held invalid.
The ruling emphasizes that statements relied upon by the Revenue must be confronted to the assessee with an opportunity of cross-examination. Failure to do so renders additions legally unsustainable.
