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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 2262 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 211717 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 444 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 84 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 63 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 135 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 93 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


Delhi HC on Reassessment Validity: AO to Examine Surviving Limitation

December 13, 2025 300 Views 0 comment Print

Delhi High Court held that reassessment notices must be individually evaluated for surviving limitation. AO directed to re-compute limitation under Rajeev Bansal framework before deciding validity.

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

December 12, 2025 816 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 705 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 651 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 618 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 306 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 3372 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 564 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 363 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 414 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.

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