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...
The Tribunal held that sanction for reopening was granted mechanically and without independent application of mind, as required under Section 151. An undated and non-speaking approval vitiated the entire reassessment proceedings.
The Tribunal held that extended block assessment beyond six years is invalid where escaped income is below ₹50 lakh. Jurisdiction under Sections 153A/153C cannot be assumed without meeting statutory limits.
ITAT affirmed that assessments for block period years must be framed only under Section 153C. Any assessment completed under Section 143(3) during such period is void in law.
The penalty was quashed as the Assessing Officer failed to strike off the inapplicable limb in the notice. Clear satisfaction and precise charge are mandatory for sustaining penalty proceedings.
The Tribunal held that assessments under Section 153A cannot be sustained when no incriminating material is found at the assessees premises. Additions based on third-party material were quashed as being without jurisdiction.
The Tribunal examined whether a single satisfaction note could sustain reassessment proceedings for multiple years under section 153C. It held that a composite satisfaction is valid when based on common seized material spanning several assessment years.
ITAT Delhi held that disallowance of bad debts claimed as deduction under section 36(1)(vii) is not justifiable if offered as income in any year. Accordingly, AO directed to verify that amount for which bad debts have claimed u/s 36(1)(vii) were indeed offered as income for the said years.
The reassessment was struck down because it relied exclusively on third-party search material. The ruling clarifies that section 153C, not section 147, must be invoked where incriminating evidence emerges from another persons search.
The Tribunal held that a protective addition cannot be termed erroneous when the same income has already been assessed substantively in another case. The twin conditions of error and prejudice under section 263 were not satisfied.
ITAT held that Section 153C proceedings were invalid as the relevant years fell beyond the six-year window. Time limitation goes to jurisdiction and cannot be cured later.
