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 appellate authority dismissed the appeal ex-parte citing non-prosecution. ITAT Delhi held that mere issuance of notices does not satisfy the requirement of effective hearing. The order was quashed and the matter sent back for fresh decision.
The Tribunal found that satisfaction under Section 153C was recorded long after the search and document transfer. Applying binding judicial precedent, ITAT ruled that the assessment was barred by limitation and therefore null and void.
The Tribunal found that alleged cash payments lacked any agreement, bank trails, or confirmation from recipients, making the addition legally untenable. ITAT emphasized adherence to evidentiary standards under Section 65B and deleted the addition entirely.
ITAT ruled that protective addition of Rs.27.74 lakh in the assessee’s hands was unjustified as the real owners of the seized gold had already been assessed.
The Rajasthan High Court ruled that a Section 148 notice for AY 2015-16 was valid as it fell within the ten-year limit for escaped income in search cases exceeding Rs.50 lakh.
Delhi High Court held that reassessment notices must be individually evaluated for surviving limitation. AO directed to re-compute limitation under Rajeev Bansal framework before deciding validity.
Delhi ITAT remands the case to CIT(A) for fresh adjudication after ex-parte dismissal. Tribunal emphasized that sufficient hearing opportunity must be granted before rejecting appeals.
ITAT Delhi held that a single Section 153D approval for multiple assessees and years is impermissible, rendering all 153A and 153C assessments void ab initio.
ITAT Mumbai deleted Section 69 additions as the Revenue relied only on uncorroborated statements and pen-drive data from third parties, violating natural justice. Suspicion alone cannot justify tax additions.
The Gujarat High Court held that information seized from a third party without a direct nexus to the petitioners cannot sustain a Section 153C notice. The AO’s action was quashed.
