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...
Income Tax : The Tribunal held that additions cannot stand without a clear link between seized material and the assessee. It ruled that third-p...
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...
Delhi ITAT held that assessments under Section 153C were invalid where the satisfaction note for the non-searched person was recorded after 01.04.2021. The Tribunal ruled that Section 153C(3) barred such proceedings, rendering the assessments void.
Delhi ITAT held that an assessment initiated through Section 153C proceedings could not be completed under Section 143(3). The Tribunal ruled that the resulting jurisdictional defect rendered the assessment invalid.
The Delhi High Court held that the period consumed in granting time to the assessee under Section 148A(b) must be excluded while computing limitation. As reassessment proceedings were initiated within time, the Section 148 notice was held valid.
ITAT Hyderabad held that reassessment beyond three years was invalid as the Assessing Officer failed to demonstrate that the alleged escaped income was represented by an asset, expenditure, or book entry as required under Section 149(1)(b). The ruling underscores the mandatory jurisdictional conditions for reopening assessments.
ITAT Delhi held that reassessment under Sections 147/148 cannot be based on the same material already examined during a completed Section 153C assessment. The ruling emphasizes that fresh tangible material is necessary for valid reopening.
The Tribunal held that the satisfaction note failed to identify the documents allegedly found during the search or their connection to the taxpayer. The ruling confirms that vague references to seized material are insufficient.
The Tribunal held that the Revenue failed to establish escaped income of ₹50 lakh or more, a prerequisite for extending the assessment period beyond six years. The ruling reinforces strict compliance with statutory thresholds for extended reassessment.
ITAT Delhi held that protective additions cannot survive when the same income has already been assessed substantively in the hands of the real beneficiaries. The key takeaway is that the Revenue cannot tax identical income twice in different hands.
The Court held that while the assessees reply period had to be excluded under Section 149, the Assessing Officer still failed to issue the Section 148 notice within the extended statutory timeline. The reassessment notice was therefore quashed as time-barred.
The Tribunal held that AY 2010-11 was outside the permissible ten-year assessment block computable under Section 153A. Applying the Delhi High Court’s interpretation in Ojjus Medicare, it found the notice itself invalid. As a result, the assessment proceedings were quashed and the appeals were allowed.
