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 : CBDT's new Compounding of Offence Guidelines (2024) simplify the process but maintain strict compliance rules. Learn about eligibi...
Income Tax : Learn about the new block assessment provisions for cases involving searches under section 132 and requisitions under section 132A...
Income Tax : Gujarat High Court held that rejection of a Vivad se Vishwas declaration was invalid because final assessment arose from survey pr...
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...
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...
Income Tax : The ITAT Hyderabad held that the assessment orders were time-barred under Section 153 despite the DRP process. Both assessments we...
Income Tax : The ITAT held that limitation under Section 153B had to be computed from the searched person's last panchanama, making the assessm...
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 issue was whether unsecured loan additions under section 68 could survive based solely on investigation reports and third-party statements. ITAT held that without independent enquiry and nexus to seized material, such additions are unsustainable.
The Tribunal reaffirmed that revision is impermissible when the Assessing Officer adopts a reasonable view after due enquiry. Section 263 cannot be invoked merely because the PCIT prefers another line of investigation.
The Tribunal deleted on-money additions where the tax department failed to establish a clear nexus between the assessee and alleged cash entries. Suspicion or unverified third-party material was held insufficient in law.
The Court held that reassessment notices failed because seized documents did not relate to the relevant assessment years. Jurisdiction under Section 153C was therefore not validly assumed.
The Tribunal held that additions based solely on third-party statements and Excel data seized from another person cannot survive without independent corroboration. Denial of effective cross-examination rendered the section 69C addition unsustainable.
Revenue argued no separate satisfaction was needed as the searched and other person had the same AO. ITAT rejected this, holding that since AOs were different on the date of satisfaction, the defect was fatal.
The dispute concerned whether the limitation period under Section 153C should be counted from the search date or from the date seized documents were handed over. The Court held that the handover date governs, excluding earlier assessment years from reassessment.
The High Court quashed tax additions where the assessee was denied cross-examination of a key witness whose statements were relied upon. The ruling reiterates that such denial violates principles of natural justice.
The issue before the Court was whether a bare approval lacking application of mind could sustain proceedings under Section 153C. The Court held that mechanical approval vitiates the proceedings, reaffirming that valid approval is a mandatory jurisdictional requirement.
ITAT Jaipur held that assessment under section 153C of the Income Tax Act stands quashed due to lack of jurisdiction since there was no transfer of the case of the assessee from Delhi to Jaipur.
