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Section 153C

Latest Articles


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 390 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 1989 Views 0 comment Print

FAQs on Compounding of Offences under Income Tax Act, 1961

Income Tax : CBDT issues new compounding guidelines simplifying process, eligibility, charges, and procedures under the Income-tax Act from Oct...

October 30, 2025 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 3381 Views 0 comment Print

Time-Barred Assessment under Section 153C: Judicial Precedents

Income Tax : AY 2015-16 assessment under Section 153C held time-barred. Judicial rulings confirm six-year limit runs from handing over of seize...

September 5, 2025 3231 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 2364 Views 0 comment Print


Latest Judiciary


Delhi HC Upholds Reassessment Notice as Time Granted for Reply is Excluddible from Limitation

Income Tax : The Delhi High Court held that the period consumed in granting time to the assessee under Section 148A(b) must be excluded while c...

June 8, 2026 132 Views 0 comment Print

ITAT Quashed Reassessment as AO Failed to Establish Escaped Income as Asset

Income Tax : ITAT Hyderabad held that reassessment beyond three years was invalid as the Assessing Officer failed to demonstrate that the alleg...

June 8, 2026 246 Views 0 comment Print

AO Cannot Reopen on the Same Material Examined in U/s 153C Assessment: ITAT Quashes ₹2.90 Crore Addition

Income Tax : ITAT Delhi held that reassessment under Sections 147/148 cannot be based on the same material already examined during a completed ...

June 6, 2026 165 Views 0 comment Print

Mechanical Satisfaction Note Invalid: ITAT Quashes 153C Assessment in Alankit Group Case

Income Tax : The Tribunal held that the satisfaction note failed to identify the documents allegedly found during the search or their connectio...

June 6, 2026 174 Views 0 comment Print

Delhi ITAT Applies Ojjus Medicare: Section 153C Assessment Beyond Six Years Quashed

Income Tax : The Tribunal held that the Revenue failed to establish escaped income of ₹50 lakh or more, a prerequisite for extending the asse...

June 6, 2026 165 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 71451 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 2514 Views 0 comment Print


One notice, rushed hearing, delayed service: ITAT restores appeal citing breach of natural justice

December 12, 2025 786 Views 0 comment Print

Delhi ITAT remands the case to CIT(A) for fresh adjudication after ex-parte dismissal. Tribunal emphasized that sufficient hearing opportunity must be granted before rejecting appeals.

Common Section 153D approval makes all search assessments void ab initio

December 12, 2025 678 Views 0 comment Print

ITAT Delhi held that a single Section 153D approval for multiple assessees and years is impermissible, rendering all 153A and 153C assessments void ab initio.

ITAT Deletes Section 69 Additions Over Unsupported On-Money Claims

December 12, 2025 633 Views 0 comment Print

ITAT Mumbai deleted Section 69 additions as the Revenue relied only on uncorroborated statements and pen-drive data from third parties, violating natural justice. Suspicion alone cannot justify tax additions.

Public information & unrelated third-party data not justifies Section 153C SCN

December 11, 2025 603 Views 0 comment Print

The Gujarat High Court held that information seized from a third party without a direct nexus to the petitioners cannot sustain a Section 153C notice. The AO’s action was quashed.

Penny-Stock Reassessments Upheld, But Ex-Parte Orders Set Aside

December 10, 2025 294 Views 0 comment Print

The Tribunal held that reopening under Section 147 was legally sound and unaffected by arguments based on 153C or Notification 18/2022. Still, it directed a full rehearing because the appellate authority issued non-speaking orders without examining the merits.

JAO cannot Sections 148A & 148 Notices Post–Notification 18/2022

December 9, 2025 3321 Views 0 comment Print

ITAT Hyderabad held that notices issued under Sections 148 and 148A by a Jurisdictional Assessing Officer were invalid, stressing only FAOs can issue such notices under the faceless assessment scheme.

Seized Papers Showing Cash Payment Treated as Credible Evidence

December 9, 2025 537 Views 0 comment Print

Detailed seized agreement and subsequent sale deed considered strong corroboration. Addition under Section 69A sustained in search-based reassessment.

Section 153C Time-Bar Checkmate: AYs Beyond 10 Years Cannot Be Touched

December 9, 2025 354 Views 0 comment Print

ITAT held that AYs 2011-12 and 2012-13 were time-barred since the 10-year window must be computed from the date of recorded satisfaction. The ruling reaffirms that out-of-range years cannot be assessed under 153C.

Cash Rebate Allegation of ₹9.06 Cr: Tribunal Rejects 7.5% Theory for Lack of Proof

December 9, 2025 393 Views 0 comment Print

The Tribunal accepted that the 7.5% rebate was a pre-negotiated commercial discount and not an unaccounted cash return. As the seized loose sheets were unverified and unsupported by witnesses, the ₹9.06 crore addition failed.

Provisions of section 153C doesn’t apply to search initiated subsequent to 01.04.2021

December 9, 2025 1509 Views 0 comment Print

Madras High Court held that the provisions of section 153C of the Income Tax Act will not apply in case of initiation of search initiated on or after 01.04.2021. Accordingly, notices issued u/s. 153C are liable to be quashed and set aside.

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