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 Chennai quashes assessment because the notice u/s 143(2) was issued by a non-jurisdictional AO after jurisdiction transfer u/s 127 was effective. Jurisdictional error is fatal; entire assessment declared void ab initio.
The Karnataka High Court ruled that when reassessment is based solely on material seized from a third-party search, the Income Tax Department must follow the specific procedure under Section 153C of the IT Act, not the general Section 147.
Delhi High Court rules ITSC applications filed until March 31, 2021, are valid and must be treated as pending. Retrospective cut-off of February 1, 2021, is arbitrary, violating Article 14.
Delhi High Court rules that a Section 153C notice for AY 2010-11 was time-barred. Citing the RRJ Securities Ltd. precedent, the Court confirms the six-year block period for an “other person” must be calculated from the date documents are handed over to the AO, not the date of the original search.
Hyderabad ITAT quashes ₹20.50 lakh tax addition based on medical college search documents. Rules third-party material needs corroboration and cross-examination.
ITAT Delhi held that regular assessment order passed under section 143(3) of the Income Tax Act without aid of section 153C despite satisfaction note from AO of searched person is not supportable in law. Thus, assessment framed u/s. 143(3) is void ab-initio.
Delhi High Court set aside notices in Kishore Kumar Sharma vs. ACIT, affirming that Section 153C proceedings require a jurisdictional AO to record prima facie satisfaction that incriminating material impacts each relevant assessment year.
The Income Tax Appellate Tribunal (ITAT), Delhi, ruled against the revenue’s additions of unaccounted capitation fees and cash loan interest under Sections 69A and 69C against the Saraswati Ammal Educational & Charitable Trust.
ITAT quashes DCIT’s 153C assessments for Piyush Bongirwar, holding that a single diary page pertaining only to AY 2013-14 cannot justify assessment for later years without specific incriminating material.
ITAT Delhi quashed Balaji Metal Tech’s assessment, ruling it void due to mechanical approval, wrong section use (143(3) instead of 153C), and failure to mention DIN in the order.
