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Section 153C

Latest Articles


FAQs on Compounding of Offences under Income Tax Act, 1961

Income Tax : The FAQs explain the revised CBDT guidelines on compounding offences under the Income-tax Act effective from 17 October 2024. They...

June 22, 2026 2262 Views 0 comment Print

All about Appeal to Income Tax Appellate Tribunal (ITAT)

Income Tax : The article explains who can file appeals before the Income Tax Appellate Tribunal, the orders that are appealable, applicable tim...

June 17, 2026 211717 Views 11 comments Print

Loose Sheets and Digital Data Not Enough: ITAT Quashes Additions for Lack of Evidence

Income Tax : The Tribunal held that additions cannot stand without a clear link between seized material and the assessee. It ruled that third-p...

May 1, 2026 444 Views 0 comment Print

Delay in Recording Satisfaction Note Under Section 153C Can Invalidate Search Proceedings

Income Tax : Judicial rulings clarify that satisfaction for initiating action against other persons in search cases must be recorded promptly. ...

March 11, 2026 2124 Views 0 comment Print

Compounding of offence under the Income-tax Act, 1961

Income Tax : CBDT's new Compounding of Offence Guidelines (2024) simplify the process but maintain strict compliance rules. Learn about eligibi...

October 17, 2025 3486 Views 0 comment Print


Latest News


Budget 2024: Block Assessment provisions for Section 132 & 132A Searches

Income Tax : Learn about the new block assessment provisions for cases involving searches under section 132 and requisitions under section 132A...

July 23, 2024 2430 Views 0 comment Print


Latest Judiciary


Vivad se Vishwas Benefit Allowed as Assessment Was Based on Survey, Not Search: Gujarat HC

Income Tax : Gujarat High Court held that rejection of a Vivad se Vishwas declaration was invalid because final assessment arose from survey pr...

June 23, 2026 66 Views 0 comment Print

Section 69 Addition Deleted as Seized Loose Sheet Lacked Corroborative Evidence

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...

June 23, 2026 84 Views 0 comment Print

ITAT Quashes Section 263 Order as Search Warrant Was Not Issued in Assessee’s Name

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...

June 23, 2026 66 Views 0 comment Print

ITAT Quashes Assessment Orders as Section 153 Limitation Expired Despite TOLA Extension

Income Tax : The ITAT Hyderabad held that the assessment orders were time-barred under Section 153 despite the DRP process. Both assessments we...

June 23, 2026 135 Views 0 comment Print

ITAT Quashes Section 153C Assessments as They Were Barred by Limitation

Income Tax : The ITAT held that limitation under Section 153B had to be computed from the searched person's last panchanama, making the assessm...

June 23, 2026 105 Views 0 comment Print


Latest Notifications


Government extends timelines for Income Tax Assessment (Read Notification)

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...

April 27, 2021 71496 Views 4 comments Print

Selection of Case of Search Years in ITBA Assessment module

Income Tax : Availability of Miscellaneous Functionalities related to ‘Selection of Case of Search Year’ and ‘Relevant Search...

September 12, 2019 2535 Views 0 comment Print


Section 153C Assessments Beyond Six-Year Block Invalid: ITAT Delhi

January 19, 2026 438 Views 0 comment Print

The Tribunal held that assessments beyond the permissible six-year block under section 153C are invalid. Proceedings were quashed as the relevant years fell outside the statutory limitation.

ITAT Chandigarh Quashes Search Assessment for Non-Compliance with New Reassessment Regime

January 19, 2026 1359 Views 0 comment Print

The issue was whether a post-search assessment could be completed under section 143(3) using third-party material. The Tribunal ruled that the special reassessment route under sections 148 and 148B was mandatory. 

Escapement Below ₹50 Lakh: ITAT Ahmedabad Holds Reopening Beyond 3 Years Invalid

January 19, 2026 768 Views 0 comment Print

The Tribunal held that reassessment beyond three years is invalid where the alleged escaped income is below ₹50 lakh. A notice issued for a ₹5 lakh donation was declared void ab initio.

Apply Reasonable Profit Rate Due to Sub-Contracts, Not 10%: ITAT Bangalore

January 19, 2026 414 Views 0 comment Print

The Tribunal held that estimating business income at 10% of turnover without citing comparable cases or industry benchmarks is unsustainable. Arbitrary profit estimation must be supported by material evidence.

Section 153C Assessments Quashed for Consolidated Satisfaction Note

January 17, 2026 615 Views 0 comment Print

The Tribunal examined whether a single, consolidated satisfaction note for multiple assessment years meets the requirement of Section 153C. It held that such consolidated recording vitiates jurisdiction, rendering the search assessments void.

Assessments Quashed for Invalid Section 153C Satisfaction Note

January 17, 2026 306 Views 0 comment Print

The case addressed the legality of assessments framed pursuant to a search when the satisfaction note lacked statutory particulars. The Tribunal quashed all assessments, holding them non-est in law due to invalid satisfaction.

Section 153C Order Invalid Without Proper Satisfaction

January 17, 2026 435 Views 0 comment Print

The tribunal held that reassessment under Section 153C cannot stand without valid satisfaction as mandated by law. Failure to examine this jurisdictional issue vitiates the proceedings.

Reopening Invalid When Search Material Triggers Section 153C

January 16, 2026 1200 Views 0 comment Print

The Tribunal held that when reassessment is based on material found during a third-party search, proceedings must be initiated under Section 153C and not Section 147. Reopening under Section 147 was therefore without jurisdiction and liable to be quashed.

Revenue Appeal Fails Due to Wrong Assessment Year for Cash Investment

January 16, 2026 621 Views 0 comment Print

Authorities added ₹8 crore as unexplained investment in the wrong year. The Tribunal confirmed that the cash component belonged to a prior year. The ruling stresses year-specific taxation of undisclosed transactions.

Bogus Purchases Partly Disallowed Due to Accepted Sales

January 16, 2026 1050 Views 0 comment Print

The case examined whether entire purchases could be treated as bogus when sales were undisputed. The Tribunal restricted the addition to 6%, holding that only a reasonable estimation was warranted.

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