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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 2268 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 3486 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 69 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 90 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 66 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 174 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 132 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


Carbon-Copy Satisfaction Note Fatal: 153C Satisfaction Mechanical Proceedings Held Void Ab Initio

November 29, 2025 441 Views 0 comment Print

The Tribunal held that notices under section 153C issued without independent satisfaction by the AO are invalid, quashing the consequent assessments for AY 2018-19 to 2020-21.

ITAT Delhi Rejects Bogus-Loan Charge; Lenders’ Creditworthiness Proven—SFIO Clean Report Saves Assessee

November 29, 2025 570 Views 0 comment Print

ITAT Mumbai confirmed loans from Hallow Securities and Dhankalash were genuine, rejecting Revenue’s allegations of shell-company loans. Interest claimed on these loans was also allowed. The ruling highlights the importance of corroborative evidence in section 68 assessments.

CIT(A) Cannot Decide on Merits Without Condoning Delay – Delhi ITAT Sets Aside Order

November 29, 2025 270 Views 0 comment Print

Delhi ITAT sets aside CIT(A) order for hearing merits despite refusing to condone an eight-month delay, highlighting the need for proper legal procedure and natural justice.

Reassessment Quashed for Issuing Section 148 Notice Beyond “Surviving Period”

November 29, 2025 450 Views 0 comment Print

The ITAT annulled the entire reassessment because the Section 148 notice was issued after the Supreme Court–mandated surviving-period cutoff. The ruling confirms that any notice beyond this timeline is void ab initio.

ITAT Strikes Down 153C Order for Copy-Paste Satisfaction Without Application of Mind

November 29, 2025 642 Views 0 comment Print

The ITAT ruled that a vague, copy-paste satisfaction note cannot confer valid jurisdiction under Section 153C. Since no specific seized documents were identified, the entire assessment was struck down.

ITAT Invalidates Consolidated Section 153D Approval for 28 Assessees

November 29, 2025 627 Views 0 comment Print

ITAT Delhi held that granting blanket 153D approval without independent examination vitiates assessments. approvals under section 153D must be individualized and carefully considered.

Section 153C Notices Beyond 10 Years Invalid: ITAT Delhi Quashes Assessments

November 27, 2025 450 Views 0 comment Print

ITAT Delhi ruled that section 153C notices for AYs 2010-11 to 2013-14 were time-barred, exceeding the 10-year limit from receipt of seized material. The Tribunal emphasized that jurisdiction under 153C requires both timeliness and relevance of incriminating material. All assessments were quashed.

LTCG Addition Remanded as CIT(A) Failed to Allow Rebuttal Opportunity

November 27, 2025 339 Views 0 comment Print

The Tribunal held that reliance on the remand report without giving the assessee a chance to rebut violated natural justice. While the jurisdiction challenge was rejected as time-barred under section 124(3), the ₹5.80 crore LTCG addition was sent back for fresh examination. The case underscores that appellate authorities must provide fair opportunity before upholding major additions.

Loose Sheets Alone Insufficient for Tax Assessment: SC upholds Quashing of Notices

November 27, 2025 942 Views 0 comment Print

High Court quashed Section 153C notices and assessment as diaries and loose sheets lacked evidentiary value, reaffirming statutory requirements for assessing income. SC Upholds HC Decision

No Satisfaction Recorded, Section 153C Cannot Be Invoked: Calcutta HC

November 27, 2025 420 Views 0 comment Print

High Court dismissed writ petition, confirming that reassessment under Section 147 is valid when no incriminating material is found, and Section 153C is inapplicable.

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