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 Tribunal ruled that third-party WhatsApp messages and decoded chat entries lacked evidentiary value against the assessee without corroborative material. The Revenue failed to prove that any cash was actually paid over and above the registered sale consideration.
The Mumbai ITAT held that Section 263 cannot be invoked merely because the Assessing Officer accepted income without making an addition after conducting enquiries. The ruling clarifies that revisionary powers require a lack of enquiry, not just a difference of opinion over the adequacy of verification.
The Mumbai ITAT held that reassessment proceedings under Section 147/148 were invalid where the case was based on search material requiring action under Section 153C. The ruling reinforces that search-related assessments for third parties must follow the special procedure under Section 153C, not regular reassessment provisions.
The Delhi ITAT found that the Assessing Officer lacked legal authority to reopen assessment years lying outside the ten-year block period computed under Section 153C. Revenue’s appeals challenging the CIT(A)’s decision were dismissed.
The Hyderabad Bench emphasized that penalty under Section 271(1)(c) cannot be imposed solely because an addition survives appellate scrutiny. The Revenue must establish deliberate concealment or furnishing of inaccurate particulars.
The Tribunal quashed the reassessment after finding that the Assessing Officer failed to issue notice under Section 143(2). The decision confirms that compliance with this statutory requirement is indispensable in reassessment proceedings.
ITAT deleted the addition after finding that neither possession nor ownership had passed during the relevant assessment year. The decision emphasizes that actual transfer, not mere intention to sell, determines taxability.
The Tribunal observed that reliance on third-party statements without providing cross-examination rendered the additions legally unsustainable. The judgment highlights the procedural safeguards available to taxpayers in search-related proceedings.
The Department argued that Section 292BC validated the approval despite alleged deficiencies, but the Tribunal rejected this contention. It held that the amendment could not apply to approvals granted before 1 April 2021. The ruling clarified that subsequent legislative changes could not cure defects in earlier approvals.
ITAT Ahmedabad held that a protective addition cannot be deleted merely because a substantive addition has been confirmed at the first appellate stage if the substantive addition is still under challenge. The ruling emphasizes that protective additions may continue until final adjudication.
