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Section 153C

Latest Articles


FAQs on Compounding of Offences under Income Tax Act, 1961

Income Tax : The FAQs explain the revised CBDT guidelines on compounding offences under the Income-tax Act effective from 17 October 2024. They...

June 22, 2026 2259 Views 0 comment Print

All about Appeal to Income Tax Appellate Tribunal (ITAT)

Income Tax : The article explains who can file appeals before the Income Tax Appellate Tribunal, the orders that are appealable, applicable tim...

June 17, 2026 211714 Views 11 comments Print

Loose Sheets and Digital Data Not Enough: ITAT Quashes Additions for Lack of Evidence

Income Tax : The Tribunal held that additions cannot stand without a clear link between seized material and the assessee. It ruled that third-p...

May 1, 2026 444 Views 0 comment Print

Delay in Recording Satisfaction Note Under Section 153C Can Invalidate Search Proceedings

Income Tax : Judicial rulings clarify that satisfaction for initiating action against other persons in search cases must be recorded promptly. ...

March 11, 2026 2124 Views 0 comment Print

Compounding of offence under the Income-tax Act, 1961

Income Tax : CBDT's new Compounding of Offence Guidelines (2024) simplify the process but maintain strict compliance rules. Learn about eligibi...

October 17, 2025 3483 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 2430 Views 0 comment Print


Latest Judiciary


Vivad se Vishwas Benefit Allowed as Assessment Was Based on Survey, Not Search: Gujarat HC

Income Tax : Gujarat High Court held that rejection of a Vivad se Vishwas declaration was invalid because final assessment arose from survey pr...

June 23, 2026 66 Views 0 comment Print

Section 69 Addition Deleted as Seized Loose Sheet Lacked Corroborative Evidence

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...

June 23, 2026 81 Views 0 comment Print

ITAT Quashes Section 263 Order as Search Warrant Was Not Issued in Assessee’s Name

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...

June 23, 2026 60 Views 0 comment Print

ITAT Quashes Assessment Orders as Section 153 Limitation Expired Despite TOLA Extension

Income Tax : The ITAT Hyderabad held that the assessment orders were time-barred under Section 153 despite the DRP process. Both assessments we...

June 23, 2026 129 Views 0 comment Print

ITAT Quashes Section 153C Assessments as They Were Barred by Limitation

Income Tax : The ITAT held that limitation under Section 153B had to be computed from the searched person's last panchanama, making the assessm...

June 23, 2026 93 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 71496 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 2535 Views 0 comment Print


Reassessment Quashed for Invalid Sanction Under Section 151(ii)

January 1, 2026 942 Views 0 comment Print

The Tribunal held that reassessment initiated after three years was void because approval was taken from an incompetent authority. The key takeaway is strict compliance with section 151(ii) is mandatory and jurisdictional.

Advance for Flat or Accommodation Loan? ITAT Remands Section 68 Addition

December 31, 2025 498 Views 0 comment Print

The Tribunal held that it was unclear whether the ₹20 lakh receipt was a loan or a property advance and remanded the matter for fresh examination. The ruling underscores that section 68 additions depend on establishing the true character of the receipt through contemporaneous evidence.

₹4 Cr Allegation Fails as Wrong Search Year Invalidates 153C Notice

December 31, 2025 273 Views 0 comment Print

The Revenue relied on alleged ₹4 crore unexplained investment to justify reopening beyond six years. The Tribunal ruled that even high-value allegations cannot override statutory limitation under section 153C.

Post-2022 Reassessment Fails for Non-Compliance with Faceless Scheme

December 31, 2025 576 Views 0 comment Print

The Tribunal quashed reassessment proceedings where the section 148 notice and section 148A(d) order were issued by the JAO instead of the FAO. It reaffirmed that post-notification violations of the faceless scheme cannot be cured by participation or waiver.

Borrowed Satisfaction Backfires: ITAT Ahmedabad Quashes 147 Reopenings Based on Dishman Group Search Inputs

December 31, 2025 729 Views 0 comment Print

ITAT held reassessment invalid as it was initiated merely on Insight Portal data and third-party statements without verification or application of mind.

JAO Can’t Reopen After Faceless Regime: ITAT Hyderabad Quashes s.148 Notices in 4 Appeals

December 31, 2025 489 Views 0 comment Print

The ITAT held that reassessment notices issued by a JAO after 29.03.2022 are void, as only a Faceless Assessing Officer can act under the faceless regime.

Beyond Six Years, Beyond Jurisdiction: Revenue Appeal Fails u/s 153C

December 30, 2025 333 Views 0 comment Print

The ITAT ruled that reassessment under section 153C cannot extend beyond the statutory six assessment years. Jurisdiction assumed outside this period was held void.

Section 153C Notice Invalid for 22-Month Delay in Recording Satisfaction

December 30, 2025 609 Views 0 comment Print

The Tribunal reaffirmed that satisfaction must be recorded contemporaneously or immediately after the searched person’s assessment. Any belated recording invalidates the assumption of jurisdiction under section 153C.

No Liability Written Back, Section 41(1) Can’t Apply

December 30, 2025 480 Views 0 comment Print

The Tribunal ruled that cessation must be evidenced by a write-back or clear act in the books. Inferences or time lapse alone cannot trigger section 41(1).

Dumb Electronic Documents Cannot Create Taxable Investment

December 30, 2025 264 Views 0 comment Print

Mumbai ITAT upholds deletion of ₹70 lakh under Section 69, ruling that uncorroborated WhatsApp scribbles from a third party cannot establish unexplained cash income.

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