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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 2262 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 3483 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 66 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 84 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 63 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 135 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 93 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


Section 263 Set Aside for Relying on Uncorroborated Dumb Documents From Third-Party Search

November 18, 2025 1134 Views 0 comment Print

ITAT held that the AO’s verification of seized material, statements, and bank records constituted proper enquiry. Key takeaway: Section 263 cannot be invoked merely because the PCIT prefers a different view.

ITAT Delhi Invalidates 153A Assessments for Lack of 153C Satisfaction

November 17, 2025 567 Views 0 comment Print

Assessments relying on third-party search material were struck down due to non-recording of satisfaction by AOs of both the searched party and the assessee. The Tribunal confirmed that 153A applies only to searches on the assessee.

Section 69 addition basis WhatsApp chats untenable sans source device/Evidence Act certificate: ITAT Mumbai

November 17, 2025 4659 Views 0 comment Print

The Tribunal held that unverified WhatsApp chats without Section 65B certification cannot justify additions under Section 69A. Key takeaway: digital messages must be authenticated and corroborated before being used against taxpayers.

ITAT Delhi Cuts Bogus Purchase Addition to 15% & Upholds 153C Jurisdiction  

November 15, 2025 1224 Views 0 comment Print

ITAT modified CIT(A)’s 20% addition on alleged bogus purchases to 15%, considering actual sales and material usage. The ruling ensures only profit embedded in disputed purchases is taxed.

Unaccounted commission addition without corroborative evidence is not sustainable

November 15, 2025 762 Views 0 comment Print

ITAT Jaipur held that addition towards unaccounted commission based on seized digital sheet without corroborative evidence is not sustainable. Accordingly, addition is deleted and said ground raised by assessee is allowed.

Unverified Third-Party Evidence Cannot Support Tax Additions, ITAT Rules

November 15, 2025 1752 Views 0 comment Print

The ITAT ruled that additions under Section 69 based solely on third-party statements and unverified documents cannot stand. Key takeaway: credible, corroborated evidence is essential for tax assessments.

Reassessment Quashed for Using Section 147 Instead of Mandatory Section 153C

November 15, 2025 1251 Views 0 comment Print

The Tribunal ruled that reassessment under section 147 was invalid where the basis of information stemmed from a third-party search. It held that such cases must mandatorily proceed under section 153C. The key takeaway: search-linked data cannot justify a section 147 reopening.

Single blanket approval under Section 153D for multiple years is invalid: ITAT Delhi

November 13, 2025 5028 Views 0 comment Print

 The ITAT held that approvals granted under Section 153D without genuine application of mind are invalid, quashing multiple assessment orders. Key takeaway: mechanical or blanket approvals violate procedural requirements and render assessments null.

Assessment u/s 153A passed with prior approval u/s 153D cannot be revised

November 13, 2025 8943 Views 0 comment Print

The Tribunal ruled that once an assessment under Section 153A is approved under Section 153D, it cannot be revised under Section 263. This reinforces limits on PCIT’s revisional powers.

No 65B Certificate, No Case: Bombay HC Quashes Cash Addition Based on Mobile Notes

November 13, 2025 1056 Views 0 comment Print

ITAT allowed the appeal where tax authority relied on uncertified electronic records to add ₹24,50,000 as unexplained cash expenditure. Ruling underscores necessity of Section 65B certification for admissibility of electronic evidence.

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