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Section 153C

Latest Articles


Budget 2025: Block Assessment Amendments in Income Tax Search Cases

Income Tax : Budget 2025 revises block assessment rules for search cases, covering undisclosed income, assessment procedures, penalties, and ti...

February 7, 2025 2106 Views 0 comment Print

Block Assessment under Chapter XIV-B of Income Tax Act, 1961

Income Tax : Explore reintroduction of block assessments under Income Tax Act via Finance Act 2024, its implications, challenges, and way forwa...

December 30, 2024 1938 Views 0 comment Print

Compounding of offence under the Income-tax Act, 1961

Income Tax : Understand the compounding of offences under the Income-tax Act, 1961, including categories, charges, and procedures as per the Fi...

September 2, 2024 1512 Views 0 comment Print

FAQs on Compounding of Offences under Income Tax Act, 1961

Income Tax : Learn about the compounding of offences under direct tax laws, including eligible offences, competent authorities, and the process...

August 23, 2024 951 Views 0 comment Print

No Incriminating Evidence, No Addition: Delhi High Court’s Ruling

Income Tax : Delhi HC rules in PCIT Vs Pavitra Realcon Pvt. Ltd., ITA 579/2018, emphasizing the need for corroborative evidence in tax assessme...

July 17, 2024 1656 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 1236 Views 0 comment Print


Latest Judiciary


Without verification, documents signed by third party cannot be held to be colourable devise

Income Tax : ITAT Jaipur held that without considering the merits of the dispute and without verifying the veracity of the documents, the docum...

May 12, 2025 780 Views 0 comment Print

Addition based on loose papers without independent corroborative material not sustained

Income Tax : ITAT Delhi held that loose papers cannot be considered as admissible evidence for making an addition unless backed by independent ...

May 10, 2025 762 Views 0 comment Print

VDIS Scheme benefit granted even in absence of original certificate of jewellery

Income Tax : ITAT Delhi held that in absence of original certificate, benefit of jewellery and ornaments declared in VDIS Scheme 1997 is grante...

May 8, 2025 168 Views 0 comment Print

10-Year Reassessment Period Unjustified as Conditions Under Section 153A(1) Not Met

Income Tax : Held that the AO seeks to disallow expenses on account of doubting the genuineness for the reason that the same were not incurred ...

May 8, 2025 333 Views 0 comment Print

Assuming jurisdiction u/s. 153C beyond block of ten years not tenable-in-law: Delhi HC

Income Tax : Delhi High Court held that since AY 2012-13 falls beyond the block of ten years that are required to be reckoned from the end of t...

May 6, 2025 117 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 69819 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 2241 Views 0 comment Print


Section 147 or 153C Assessment – Search from 3rd party premises – Unexplained Money addition under Section 69A

May 24, 2021 10020 Views 0 comment Print

ACIT Vs. K. S. Chawla & Sons (HUF) (ITAT Delhi) > HELD THAT:- In the present assessee’s case, search & seizure action u/s 132 of the Act was carried out on 15.10.2009 in the premises of Mr. Abhinav Arora and Mrs. Ranju Arora. Consequently, the Assessing Officer initiated reassessment proceedings u/s 147 of the Act […]

Government extends timelines for Income Tax Assessment (Read Notification)

April 27, 2021 69819 Views 4 comments Print

Central Government has decided to extend the time limits to 30th June, 2021 in the following cases where the time limit was earlier extended to 30th, April 2021 through various notifications issued under the Taxation and Other Laws (Relaxation) and Amendment of Certain Provisions Act, 2020, namely:-

Section 153A Search Assessment- No addition if No incriminating material

April 24, 2021 1509 Views 0 comment Print

In search assessment, any undisclosed income, which can ultimately be added, is only to the extent of any unrecorded assets/material found or any incriminating documents found as representing undisclosed income earned, since, AO had not made any specific reference to the incriminating material found during the search in respect of additions made by him, therefore, assessment so framed, was bad in law.

Search proceedings valid if jurisdictional facts exist for assumption of section 153A & 153C jurisdiction

April 24, 2021 975 Views 0 comment Print

S. R. Trust Vs ACIT (Madras High Court) Conclusion: Search proceedings had been rightly initiated as assessee had nothing to fear, they could as well place all the materials before AO for consideration and more so, the jurisdictional facts exist for assumption of jurisdiction under Section 153A as well as Section 153C of the Act. […]

No Section 153C addition in case no incriminating material found

April 12, 2021 2691 Views 0 comment Print

ACIT Vs Himalaya Darshan Developers (Gujarat) Pvt. Ltd. (ITAT Ahmedabad) The question that arises for our adjudication whether the document in the form of tally and balance sheet found during the course of search is an incriminating document in nature. In our considered view such document are not an incriminating material, as such those documents […]

Section 153C Assessment invalid if Satisfaction not recorded & If section 153C notice not issued

April 6, 2021 3558 Views 0 comment Print

No satisfaction note have been recorded under section 153C of the I.T. Act. The A.O. passed the assessment order for the assessment year under appeal i.e., 2013-2014 under section 143(3) considering the preceding A.Y. 2012-2013 to the year of the search.

No Section 2(22)(e) addition if money lending was part of business

March 4, 2021 717 Views 0 comment Print

M.L. Singhi & Associates (P) Ltd. Vs DCIT (ITAT Delhi) No addition could be made against the assessee if no incriminating material was found during the course of search It is not in dispute that whatever queries were raised by the A.O. time to time, have been replied by assessee along with documentary evidences. All […]

Addition cannot be made on the basis of mere diary jottings

February 22, 2021 5217 Views 0 comment Print

D.S. Suresh vs ACIT (ITAT Bangalore) In the present case, the addition is based on the diary jottings found during the course of search action in the case of RNSIL on 16.02.2012. We have carefully gone through the diary jottings recorded earlier part of this order. It contains the entry No.5 – MLA Tarikere Rs.27 […]

HC explains validity of invocation of section 153A based on statement recorded in search action against a third person

February 12, 2021 3657 Views 0 comment Print

Section 153A Invalid Where Statement Belonging And Pertaining To Person Other Than Searched Person Used To Assume Jurisdiction and Only Section 153C Can Be Invoked And Without Cross Examination Of Witness There Can Be No Valid Proceedings Under Law.   

Section 153C: ITAT directs CIT(A) to examine recording of satisfaction

February 8, 2021 996 Views 0 comment Print

R.N. Shetty Trust Vs ACIT (ITAT Bangalore) As per Section 153C of the Act, the Assessing Officer of searched person shall proceed against such other person on reaching satisfaction that any undisclosed income belonging to such other person over whom he has no jurisdiction then he has to transmit the seized material to the Assessing […]

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