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 Delhi held that reassessment for AY 2010-11 was invalid since it exceeded the ten-year limitation from the search year. The notice was declared time-barred and issued without jurisdiction.
TAT Delhi held that a 153C assessment for AY 2012–13 was invalid, as the six-year block must be counted from date of satisfaction recorded by AO of non-searched person.
ITAT Delhi held that ten-year block under Section 153C must be computed from date AO of non-searched person receives seized material, not search date.
ITAT Delhi held that assessments for A.Ys 2011–12 and 2012–13 were invalid since they fell outside the ten-year block reckoned from the date of receipt of seized material. The Tribunal followed CIT v. Jasjit Singh (SC) and Ojjus Medicare (Del HC) rulings.
Kerala High Court dismissed a writ petition challenging a Section 153C assessment, ruling that the ITAT had already addressed the Abhisar Buildwell Supreme Court judgment. Since the ITAT order contained a finding on the judgment’s applicability, the assessee’s only recourse was a statutory appeal under Section 260A.
Bombay High Court ruled that transferring a taxpayer’s case is unnecessary when assessment for relevant year has already been finalized, quashing earlier impugned order.
ITAT Chandigarh quashed an assessment order made under Section 143(3) for a pre-search year, holding that after a Section 132 search, the assessment must mandatorily proceed under Section 148 with proper Section 148B approval. The tribunal ruled that the Assessing Officer’s continuation of the scrutiny post-search was a jurisdictional error, making the assessment void ab initio.
ITAT Chennai held that when sales are accepted and supported by records, entire purchases cannot be treated as bogus merely because suppliers were untraceable. Addition restricted to 12.5% as profit element.
ITAT Hyderabad held that reopening of assessment is invalid in as much as the approval/ sanction under section 151 of the Income Tax Act is granted in a mechanical manner. Further, reasons for reopening are based on on-application of mind and borrowed satisfaction. Accordingly, reopening quashed and appeal allowed.
ITAT Delhi held that assessments under Section 153C were invalid where AO recorded a vague, consolidated satisfaction note without linking seized material to specific assessment years.
