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 corrected its earlier order after noting that the liberty to reopen completed assessments under sections 147/148 was omitted. The ruling clarifies that absence of incriminating material bars search additions but not lawful reassessment.
The Revenue made additions on alleged penny-stock transactions under section 68. The ITAT held that once section 153C jurisdiction itself fails, the additions automatically fall without examination on merits.
Despite allegations of sham sub-contracts, the project was shown to be completed, commissioned and operational. The Tribunal held that once the asset exists and is used, depreciation cannot be denied without concrete proof of bogus cost.
ITAT Delhi held that mere Whatsapp messages showing demand do not justify Section 69A additions unless actual receipt of money is proved.
Upholding the appellate authority, the Tribunal confirmed that jurisdiction cannot be assumed casually against a non-searched person. Statutory satisfaction requirements are mandatory, not procedural.
The ITAT held that reassessment based purely on an Investigation Wing report, without the Assessing Officer forming an independent belief, is invalid. Copy-pasted reasons failed to establish a live link between material and escapement of income.
The question was whether the extended ten-year window under Section 153C could be invoked. The Tribunal held that where the satisfaction note shows escaped income below ₹50 lakh, the extended limitation is unavailable.
The ITAT held that once an assessee’s premises are searched, proceedings must be under Section 153A. Invoking Section 153C in such cases is a jurisdictional error.
ITAT held that on-money admitted by a seller before the Settlement Commission cannot be presumed against the purchaser without independent evidence. In absence of any seized material or proof of cash payment, the addition u/s 69 was deleted.
The case examined whether assessments under Section 153C were valid without proper recording of statutory satisfaction. The Court remanded the matter, holding that jurisdiction must be decided before examining additions on merits.
