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Section 153C

Latest Articles


FAQs on Compounding of Offences under Income Tax Act, 1961

Income Tax : The FAQs explain the revised CBDT guidelines on compounding offences under the Income-tax Act effective from 17 October 2024. They...

June 22, 2026 2250 Views 0 comment Print

All about Appeal to Income Tax Appellate Tribunal (ITAT)

Income Tax : The article explains who can file appeals before the Income Tax Appellate Tribunal, the orders that are appealable, applicable tim...

June 17, 2026 211714 Views 11 comments Print

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 441 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 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 3483 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 2430 Views 0 comment Print


Latest Judiciary


Vivad se Vishwas Benefit Allowed as Assessment Was Based on Survey, Not Search: Gujarat HC

Income Tax : Gujarat High Court held that rejection of a Vivad se Vishwas declaration was invalid because final assessment arose from survey pr...

June 23, 2026 66 Views 0 comment Print

Section 69 Addition Deleted as Seized Loose Sheet Lacked Corroborative Evidence

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...

June 23, 2026 69 Views 0 comment Print

ITAT Quashes Section 263 Order as Search Warrant Was Not Issued in Assessee’s Name

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...

June 23, 2026 51 Views 0 comment Print

ITAT Quashes Assessment Orders as Section 153 Limitation Expired Despite TOLA Extension

Income Tax : The ITAT Hyderabad held that the assessment orders were time-barred under Section 153 despite the DRP process. Both assessments we...

June 23, 2026 102 Views 0 comment Print

ITAT Quashes Section 153C Assessments as They Were Barred by Limitation

Income Tax : The ITAT held that limitation under Section 153B had to be computed from the searched person's last panchanama, making the assessm...

June 23, 2026 84 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 71496 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 2535 Views 0 comment Print


Reassessment Fails When Jurisdictional Officer Issues Section 148 Notice

December 23, 2025 2589 Views 0 comment Print

The Tribunal held that after 29-03-2022, only a Faceless Assessing Officer is empowered to issue notices under Section 148. Notices issued by a jurisdictional officer were declared void, vitiating the entire reassessment.

ITAT Bangalore: Section 148 Valid, Reassessment Set Aside for Non-Supply of Reasons

December 23, 2025 732 Views 0 comment Print

ITAT Bangalore invalidated a reassessment where the assessee was not provided the recorded reasons, emphasizing that reopening notices must be supported by clear, communicated reasons before filing returns.

153C Time-Barred: ITAT Quashes Assessments Outside Block Period Based on Satisfaction Note Date

December 23, 2025 510 Views 0 comment Print

Delhi ITAT ruled that assessments for AYs 2010-11 to 2012-13 under section 153C were invalid as the statutory block period starts from the satisfaction note date, not the original search.

Reassessment Notice Held Valid Because SCN Period Is Excluded from Limitation: ITAT Mumbai

December 22, 2025 720 Views 0 comment Print

The dispute centered on whether a reassessment notice was time-barred and sanctioned by the correct authority. The Tribunal held that the reply period under section 148A must be excluded, bringing the notice within three years and validating the sanction.

One Satisfaction Note for Seven Years Invalidates Section 153C: ITAT Pune

December 22, 2025 486 Views 0 comment Print

The issue was whether section 153C could extend beyond six years without discovery of an undisclosed asset of ₹50 lakh or more. The ITAT held that in absence of such asset-based satisfaction, extended jurisdiction is invalid.

No U/s 153A Addition, But Reassessment Power Explicitly Preserved

December 22, 2025 327 Views 0 comment Print

The ITAT corrected its earlier order after noting that the liberty to reopen completed assessments under sections 147/148 was omitted. The ruling clarifies that absence of incriminating material bars search additions but not lawful reassessment.

Earlier Section 263 Action Cannot Justify Fresh 153C Assessment

December 22, 2025 354 Views 0 comment Print

The Revenue made additions on alleged penny-stock transactions under section 68. The ITAT held that once section 153C jurisdiction itself fails, the additions automatically fall without examination on merits.

Depreciation Disallowance Quashed Due to Lack of Incriminating Material

December 21, 2025 333 Views 0 comment Print

Despite allegations of sham sub-contracts, the project was shown to be completed, commissioned and operational. The Tribunal held that once the asset exists and is used, depreciation cannot be denied without concrete proof of bogus cost.

Whatsapp Chats Insufficient for Section 69A Addition Without Proof of Receipt: ITAT Delhi

December 21, 2025 318 Views 0 comment Print

ITAT Delhi held that mere Whatsapp messages showing demand do not justify Section 69A additions unless actual receipt of money is proved.

Section 153C Notice Invalid Due to Missing ₹50 Lakh Asset Satisfaction

December 21, 2025 516 Views 0 comment Print

Upholding the appellate authority, the Tribunal confirmed that jurisdiction cannot be assumed casually against a non-searched person. Statutory satisfaction requirements are mandatory, not procedural.

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