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 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 about the new block assessment provisions for cases involving searches under section 132 and requisitions under section 132A...
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...
Income Tax : ITAT Hyderabad held that reassessment beyond three years was invalid as the Assessing Officer failed to demonstrate that the alleg...
Income Tax : ITAT Delhi held that reassessment under Sections 147/148 cannot be based on the same material already examined during a completed ...
Income Tax : The Tribunal held that the satisfaction note failed to identify the documents allegedly found during the search or their connectio...
Income Tax : The Tribunal held that the Revenue failed to establish escaped income of ₹50 lakh or more, a prerequisite for extending the asse...
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...
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.
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 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.
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.
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.
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.
Detailed seized agreement and subsequent sale deed considered strong corroboration. Addition under Section 69A sustained in search-based reassessment.
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.
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.
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.
