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Section 153C

Latest Articles


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 1569 Views 0 comment Print

FAQs on Compounding of Offences under Income Tax Act, 1961

Income Tax : CBDT issues new compounding guidelines simplifying process, eligibility, charges, and procedures under the Income-tax Act from Oct...

October 30, 2025 1968 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 2940 Views 0 comment Print

Time-Barred Assessment under Section 153C: Judicial Precedents

Income Tax : AY 2015-16 assessment under Section 153C held time-barred. Judicial rulings confirm six-year limit runs from handing over of seize...

September 5, 2025 2721 Views 0 comment Print

Consolidated Satisfaction Note under Section 153C Held Invalid

Income Tax : Learn why a consolidated satisfaction note for multiple assessment years is legally invalid under Section 153C of the Income Tax A...

September 5, 2025 1764 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 2127 Views 0 comment Print


Latest Judiciary


Section 153C Assessment Quashed Over Unsigned Seized Document: ITAT Hyderabad

Income Tax : The Tribunal held that an unsigned agreement without corroboration cannot be treated as incriminating material. Proceedings under ...

April 18, 2026 72 Views 0 comment Print

On-Money Addition Based on Excel Sheet Deleted: No Corroborative Evidence

Income Tax : The Tribunal deleted additions where the Revenue failed to prove actual cash transactions. It emphasized that suspicion and assump...

April 18, 2026 201 Views 0 comment Print

Reassessment Quashed as Wrong Provision Invoked Instead of Section 153C: ITAT Jaipur

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...

April 17, 2026 498 Views 0 comment Print

Reopening Fails on Both Counts: Invalid Sec 148A Notice and Time-Barred Sec 148 Render Assessment Void

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...

April 16, 2026 171 Views 0 comment Print

Bombay HC Quashed Section 153C Proceedings Due to Delay in Recording Satisfaction Note

Income Tax : The Court held that a 21-month delay in recording the satisfaction note violates the requirement of immediacy. It ruled that such ...

April 15, 2026 204 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 71214 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 2466 Views 0 comment Print


No Section 147 Reopening on Third-Party Search Material: ITAT Raipur

September 23, 2025 717 Views 0 comment Print

The ITAT Raipur quashed the reopening of an assessment under Section 147, ruling that search-based cases on third-party material must be initiated under Section 153C.

Opportunity of being heard granted as assessment completed on best judgement due to non-response by petitioner

September 22, 2025 486 Views 0 comment Print

Madras High Court held that completion of assessment on best judgement as the petitioner had not shown cause in response to the notice vis-à-vis assessment made after several years of return filing. Hence, matter restored back for providing opportunity of being heard to petitioner.

Section 153A Additions Made Without Incriminating Material are Invalid: ITAT Delhi

September 21, 2025 345 Views 0 comment Print

The ITAT has deleted gross profit additions made to Sunil Garg’s income, ruling that the Assessing Officer’s actions were arbitrary and lacked incriminating material.

ITAT Raipur Sets Aside Penalty for Lack of Adequate Hearing

September 19, 2025 333 Views 0 comment Print

The Raipur ITAT remanded the Omax Minerals tax case back to CIT(A) after finding that the company was denied a fair opportunity to be heard in a penalty proceeding. The ruling cites procedural irregularities.

Mere disclosure of additional income under 153C not concealment of Income

September 15, 2025 267 Views 0 comment Print

The Income Tax Appellate Tribunal (ITAT) in Cochin has ruled that voluntarily disclosing additional income after a search notice does not automatically justify a penalty under Section 271(1)(c) of the Income-tax Act, 1961.

ITAT Pune Quashes Reassessment u/s 147, Says Search Cases Must Proceed u/s 153C

September 15, 2025 771 Views 0 comment Print

The Pune ITAT quashed a reassessment order, ruling that proceedings initiated under Section 147 were invalid. The tribunal held that information from a third-party search mandates proceedings under Section 153C, not Section 147.

Search-Based Assessment Falls Under Section 153C, Not 147 – ITAT Bangalore Quashes Addition

September 5, 2025 726 Views 0 comment Print

The ITAT Bangalore has quashed a reassessment order, ruling that a tax addition based on documents seized in a third-party search must be made under Section 153C, not 147.

No Incriminating Material, No 153C – ITAT Bangalore Deletes ₹150+ Cr Additions in JDA Case

September 5, 2025 1239 Views 0 comment Print

ITAT Bangalore deletes ₹150+ crore additions, quashing assessment due to lack of incriminating material and multiple jurisdictional defects in the proceedings.

Time-Barred Assessment under Section 153C: Judicial Precedents

September 5, 2025 2721 Views 0 comment Print

AY 2015-16 assessment under Section 153C held time-barred. Judicial rulings confirm six-year limit runs from handing over of seized documents to AO.

No Incriminating Material, No Addition – ITAT Bangalore Deletes Suppression Additions

September 5, 2025 432 Views 0 comment Print

ITAT Bangalore deletes additions in the KC Raju Hospital case, confirming that no additions can be made to unabated assessment years without specific incriminating material.

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