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. ...
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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...
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Income Tax : Availability of Miscellaneous Functionalities related to ‘Selection of Case of Search Year’ and ‘Relevant Search...
The issue was whether cash found at a third party’s premises could be added in the assessee’s 153A assessment. The Tribunal held such additions invalid, ruling that proceedings must be initiated under section 153C.
The Tribunal ruled that additions for alleged cash payments cannot survive when based solely on third-party statements and unverified electronic data. Absence of corroboration and denial of cross-examination violated principles of natural justice.
The Tribunal clarified that revisionary jurisdiction presupposes a valid assessment order. Where Section 153C itself is time-barred, Section 263 has no application.
The Tribunal held that revision under Section 263 cannot be exercised over a search assessment completed under Section 153C with proper approval under Section 153D. Unless such approval is shown to be erroneous, revisional jurisdiction does not arise.
Revenue issued 153C notices for years far preceding the satisfaction date. Following binding judicial precedent, the tribunal ruled that such assessments were beyond the ten-year statutory window and could not survive.
Where income admitted in section 153C proceedings is accepted in assessment, penalty still requires strict compliance with section 270A. Absence of a specific misreporting charge defeats penalty levy.
The Tribunal held that reassessment under section 147 fails when seized search material exists. The correct and exclusive route is section 153C, making the reopening jurisdictionally invalid.
The Tribunal held that an assessment under section 153C cannot go beyond the material specified in the satisfaction note. Since additions were based on different material, the entire assessment was quashed.
The Tribunal held that after the High Court invalidated section 153C proceedings, all subsequent tax adjustments including those involving ₹6.68 crore are unsustainable. Judicial finality bars further action.
The Tribunal dismissed the Revenue’s appeal, holding that JDA-related income issues had already attained finality. Any attempt to reassess the same income in an earlier year would result in impermissible double taxation.
