Income Tax : The FAQs explain the revised CBDT guidelines on compounding offences under the Income-tax Act effective from 17 October 2024. They...
Income Tax : The article explains who can file appeals before the Income Tax Appellate Tribunal, the orders that are appealable, applicable tim...
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Income Tax : Judicial rulings clarify that satisfaction for initiating action against other persons in search cases must be recorded promptly. ...
Income Tax : CBDT's new Compounding of Offence Guidelines (2024) simplify the process but maintain strict compliance rules. Learn about eligibi...
Income Tax : Learn about the new block assessment provisions for cases involving searches under section 132 and requisitions under section 132A...
Income Tax : Gujarat High Court held that rejection of a Vivad se Vishwas declaration was invalid because final assessment arose from survey pr...
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...
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...
Income Tax : The ITAT Hyderabad held that the assessment orders were time-barred under Section 153 despite the DRP process. Both assessments we...
Income Tax : The ITAT held that limitation under Section 153B had to be computed from the searched person's last panchanama, making the assessm...
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...
Tribunal emphasizes requirement of notice under section 153C for assessments in block period, quashing AY 2021-22 assessment framed without jurisdiction.
ITAT Jaipur held that addition made on the basis of documents found from the third party without providing any opportunity of cross-examination is liable to be deleted on the ground of violation of principles of natural justice.
ITAT Delhi held that assessments under section 153C are invalid if the AO of the searched person fails to record a mandatory satisfaction note, emphasizing jurisdictional compliance.
The decision highlights that additions under Section 153C cannot stand when based only on third-party statements without seized material linking the assessee. The ruling stresses the need for concrete evidence before treating purchases as non-genuine.
The Court held that the search was valid after reviewing the recorded reasons and information. It ruled that jurisdiction existed under Section 132 and that challenges to procedural aspects did not invalidate the search.
ITAT Chennai struck down a protective addition of ₹14.91 Cr made u/s 69, citing invalid u/s 153C jurisdiction. No substantive assessment existed in the companies’ hands for AY 2014-15, reinforcing that protective additions require year-wise satisfaction and corroborative evidence.
ITAT held that additions under section 153A cannot be made if no incriminating material is found at the assessee’s premises; third-party documents should be invoked via section 153C.
The Tribunal held that a cash ledger found during a third-party search could not trigger Section 153C when the assessee’s name was absent. It ruled that additions fail without a direct link to the assessee.
The Department could not produce a single document seized from the assessee, relying only on third-party statements, which are not incriminating material. The JCIT’s same-day clearance of multiple assessments without analysis led to the assessments being quashed.
The Tribunal examined the validity of assessments initiated under Section 153C where the Assessing Officer recorded a single consolidated satisfaction note for multiple assessment years. Following binding precedents, the Tribunal held that consolidated satisfaction is a fatal jurisdictional error and quashed the 153C assessments entirely.
