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...
The ITAT ruled that additions under Section 69 based solely on third-party statements and unverified documents cannot stand. Key takeaway: credible, corroborated evidence is essential for tax assessments.
The Tribunal ruled that reassessment under section 147 was invalid where the basis of information stemmed from a third-party search. It held that such cases must mandatorily proceed under section 153C. The key takeaway: search-linked data cannot justify a section 147 reopening.
The ITAT held that approvals granted under Section 153D without genuine application of mind are invalid, quashing multiple assessment orders. Key takeaway: mechanical or blanket approvals violate procedural requirements and render assessments null.
The Tribunal ruled that once an assessment under Section 153A is approved under Section 153D, it cannot be revised under Section 263. This reinforces limits on PCIT’s revisional powers.
ITAT allowed the appeal where tax authority relied on uncertified electronic records to add ₹24,50,000 as unexplained cash expenditure. Ruling underscores necessity of Section 65B certification for admissibility of electronic evidence.
The Tribunal held that CIT(A) must decide all grounds, including legality of reopening under Section 147/148. Order remanded for fresh adjudication under Section 250(6).
ITAT Chennai ruled that an assessment order issued without a Document Identification Number violates CBDT Circular No. 19/2019 and is invalid. Tribunal held that non-compliance with circular’s mandate cannot be cured by later communication of DIN. Orders lacking DIN are deemed never to have been issued.
The Delhi High Court held that reassessment under Section 153C cannot exceed the ten-year block calculated from the date of handover of seized materials, setting aside notices for AYs 2010–11 to 2015–16.
Once the order of ITAT had attained finality on factual aspects and assessee had discharged the entire liability, the Tax Recovery Officer was bound, under Section 225(2) to lift the attachment on property.
Delhi ITAT held that AYs 2010–11 and 2011–12 fell outside the limitation for Section 153C and found no valid incriminating material for later years, setting aside all related assessments.
