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...
Learn why a consolidated satisfaction note for multiple assessment years is legally invalid under Section 153C of the Income Tax Act, based on recent court rulings.
Under Section 153C, the six-year limitation period for issuing a notice to a person other than the one searched begins from the date on which the documents or materials were received by AO, not from the date of the search or notice.
ITAT Mumbai dismissed Revenue’s appeal, upholding deletion of a Rs. 16 lakh penalty against Micro Plantea Limited due to a lack of incriminating material in a search assessment.
The Patna ITAT holds that Section 69 applies even without books of account, but remands a case for fresh verification after the assessee provided new evidence of earlier cash payments.
ITAT Bangalore quashes assessments against Blueline Foods, ruling that a survey is not a valid search and that a panchanama in the company’s name is required.
If any assessment proceedings are to be initiated by AO by relying on any information found during search action conducted on third party, then the Dept must resort to special provisions of section 153C and notice issued u/s 148 in such scenario is bad in law.
The Delhi ITAT has invalidated assessments under Section 153C, ruling that a consolidated and mechanical approval under Section 153D is not valid. The approval must be specific to each year.
Delhi ITAT quashes ₹11 crore in tax additions, ruling that additions in a search case cannot be made without finding incriminating material on the assessee’s premises.
Additions made under section 69A against assessee for Assessment Years (AYs) 2011-12 to 2018-19 was deleted as proceedings initiated on the basis of seized documents which did not mention assessee’s name were unsustainable.
Tribunal upheld revision. It was held that once there was an inquiry, even inadequate, that would not by itself, give occasion to the Commissioner to pass order under Section 263 merely because he had a different opinion in the matter.
