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 granting blanket 153D approval without independent examination vitiates assessments. approvals under section 153D must be individualized and carefully considered.
ITAT Delhi ruled that section 153C notices for AYs 2010-11 to 2013-14 were time-barred, exceeding the 10-year limit from receipt of seized material. The Tribunal emphasized that jurisdiction under 153C requires both timeliness and relevance of incriminating material. All assessments were quashed.
The Tribunal held that reliance on the remand report without giving the assessee a chance to rebut violated natural justice. While the jurisdiction challenge was rejected as time-barred under section 124(3), the ₹5.80 crore LTCG addition was sent back for fresh examination. The case underscores that appellate authorities must provide fair opportunity before upholding major additions.
High Court quashed Section 153C notices and assessment as diaries and loose sheets lacked evidentiary value, reaffirming statutory requirements for assessing income. SC Upholds HC Decision
High Court dismissed writ petition, confirming that reassessment under Section 147 is valid when no incriminating material is found, and Section 153C is inapplicable.
Tribunal emphasizes requirement of notice under section 153C for assessments in block period, quashing AY 2021-22 assessment framed without jurisdiction.
ITAT Jaipur held that addition made on the basis of documents found from the third party without providing any opportunity of cross-examination is liable to be deleted on the ground of violation of principles of natural justice.
ITAT Delhi held that assessments under section 153C are invalid if the AO of the searched person fails to record a mandatory satisfaction note, emphasizing jurisdictional compliance.
The decision highlights that additions under Section 153C cannot stand when based only on third-party statements without seized material linking the assessee. The ruling stresses the need for concrete evidence before treating purchases as non-genuine.
The Court held that the search was valid after reviewing the recorded reasons and information. It ruled that jurisdiction existed under Section 132 and that challenges to procedural aspects did not invalidate the search.
