Income Tax : This document provides a complete reference on compounding of offences, including application procedures, offence-wise charges, re...
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. ...
Income Tax : Learn about the new block assessment provisions for cases involving searches under section 132 and requisitions under section 132A...
Income Tax : ITAT Delhi deleted Section 271(1)(c) penalty after holding that no incriminating material was found and the assessment accepted th...
Income Tax : ITAT Delhi quashed assessments for multiple years, citing defects in reassessment approvals, non-supply of material, invalid reope...
Income Tax : ITAT Ahmedabad held that reassessment under Section 147 was invalid where proceedings should have been initiated under Section 153...
Income Tax : Delhi High Court dismissed the Revenues appeal, holding that no substantial question of law arose where additions were based on un...
Income Tax : ITAT Mumbai quashed reassessment under Sections 147/148, holding search-based proceedings founded on seized material had to follow...
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...
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
