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 struck down ₹17.5 lakh salary disallowance under Section 40A(2)(b) because the AO relied on a statement of a different person. Standalone statements without corroboration cannot sustain additions.
ITAT held that reopening of assessment based solely on investigation inputs without independent verification is invalid. The reassessment and 1% commission addition were deleted, reinforcing the requirement for AO’s own application of mind.
Because the approval was issued collectively for several years, the Tribunal found it invalid and allowed the appeal. The key takeaway is the necessity of separate approval for each year.
ITAT Delhi held that AY 2011-12 is barred by limitation under Section 153C as the deemed search year started only when documents were received in 2021, nullifying the reassessment and related penalties.
Genuine sale was established through invoices, stock records, ledgers, bank proofs, and direct buyer confirmations, leaving no room for Section 68 additions. ITAT held that when sales are proved, no commission can be presumed under Section 69C.
The Tribunal held that notices under section 153C issued without independent satisfaction by the AO are invalid, quashing the consequent assessments for AY 2018-19 to 2020-21.
ITAT Mumbai confirmed loans from Hallow Securities and Dhankalash were genuine, rejecting Revenue’s allegations of shell-company loans. Interest claimed on these loans was also allowed. The ruling highlights the importance of corroborative evidence in section 68 assessments.
Delhi ITAT sets aside CIT(A) order for hearing merits despite refusing to condone an eight-month delay, highlighting the need for proper legal procedure and natural justice.
The ITAT annulled the entire reassessment because the Section 148 notice was issued after the Supreme Court–mandated surviving-period cutoff. The ruling confirms that any notice beyond this timeline is void ab initio.
The ITAT ruled that a vague, copy-paste satisfaction note cannot confer valid jurisdiction under Section 153C. Since no specific seized documents were identified, the entire assessment was struck down.
