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...
ITAT Delhi held that without a clear and direct connection between the facts and the alleged escapement of income, the reasons recorded remains speculative, therefore, the reopening cannot be justified. Accordingly, appeal allowed to that extent.
The ITAT held that undated satisfaction notes defeat jurisdiction under section 153C. In such cases, limitation must be computed from the notice date, making assessments beyond the block period void.
The Tribunal examined whether an addition under section 153C could survive without seized material. It held that in an unabated year, additions are impermissible without incriminating evidence found during search, leading to deletion of the addition.
ITAT Delhi clarified that Section 153A is not meant to reassess completed years in absence of seized evidence. The ₹6.11 lakh addition was therefore held to be without jurisdiction.
The issue was whether a completed assessment could be revised without identifying concrete errors. The Tribunal held that vague observations and absence of specific defects do not justify invoking section 263.
Karnataka High Court held that provisions of section 153C of the Income Tax Act cannot be invoked since the petitioner was a searched person and not a non-searched person / such other person. Accordingly, the proceedings quashed.
ITAT Delhi held that Section 153C proceedings cannot proceed on mere suspicion; the AO must establish that seized material impacts the assessee’s total income. The assessments for AYs 2018-19 and 2019-20 were fully quashed.
The ITAT Delhi invalidated assessments where the AO failed to record year-wise satisfaction linking seized material to the assessee. Proper satisfaction is essential for initiating Section 153C proceedings.
PCIT invoked section 263 against an assessment under section 153C. ITAT held that without challenging statutory 153D approval, revision is unsustainable, emphasizing that 153D is a statutory safeguard.
PCIT challenged a 153C assessment under section 263. ITAT held that without annulling statutory 153D approval, revision is unsustainable, confirming 153D as a statutory safeguard.
