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 Chennai struck down a protective addition of ₹14.91 Cr made u/s 69, citing invalid u/s 153C jurisdiction. No substantive assessment existed in the companies’ hands for AY 2014-15, reinforcing that protective additions require year-wise satisfaction and corroborative evidence.
ITAT held that additions under section 153A cannot be made if no incriminating material is found at the assessee’s premises; third-party documents should be invoked via section 153C.
The Tribunal held that a cash ledger found during a third-party search could not trigger Section 153C when the assessee’s name was absent. It ruled that additions fail without a direct link to the assessee.
The Department could not produce a single document seized from the assessee, relying only on third-party statements, which are not incriminating material. The JCIT’s same-day clearance of multiple assessments without analysis led to the assessments being quashed.
The Tribunal examined the validity of assessments initiated under Section 153C where the Assessing Officer recorded a single consolidated satisfaction note for multiple assessment years. Following binding precedents, the Tribunal held that consolidated satisfaction is a fatal jurisdictional error and quashed the 153C assessments entirely.
ITAT held that the AO’s verification of seized material, statements, and bank records constituted proper enquiry. Key takeaway: Section 263 cannot be invoked merely because the PCIT prefers a different view.
Assessments relying on third-party search material were struck down due to non-recording of satisfaction by AOs of both the searched party and the assessee. The Tribunal confirmed that 153A applies only to searches on the assessee.
The Tribunal held that unverified WhatsApp chats without Section 65B certification cannot justify additions under Section 69A. Key takeaway: digital messages must be authenticated and corroborated before being used against taxpayers.
ITAT modified CIT(A)’s 20% addition on alleged bogus purchases to 15%, considering actual sales and material usage. The ruling ensures only profit embedded in disputed purchases is taxed.
ITAT Jaipur held that addition towards unaccounted commission based on seized digital sheet without corroborative evidence is not sustainable. Accordingly, addition is deleted and said ground raised by assessee is allowed.
