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...
ITAT Surat held that reopening of assessment under section 148 of the Income Tax Act without tangible material tantamount to change of opinion on the existing facts and the same is impermissible in law. Accordingly, appeal allowed and reopening quashed.
ITAT Pune held that satisfaction note is required to be recorded u/s 153C for each assessment year and a consolidated satisfaction note recorded for different assessment years would vitiate the entire assessment proceedings. Accordingly, appeal of revenue dismissed.
ITAT Mumbai held that where the entire foundation of reopening solely based on material found during the search of another person, the appropriate course of action is to proceed under Section 153C, and not under Section 147. Accordingly, reassessment proceedings u/s. 147 quashed.
The Kerala High Court clarified eligibility for Income Tax Settlement applications, quashing a CBDT condition and allowing a delayed filing due to Supreme Court’s COVID-19 limitation extension.
Delhi High Court rules that a tax refund cannot be denied for a TDS mismatch if the assessee timely filed a revised return, and revenue neither rejected it nor communicated defects.
ITAT Pune invalidated 153C assessments in the Yuvraj Dhamale group case, citing jurisdictional errors due to Settlement Commission involvement, consolidated satisfaction notes, and mechanical Section 153D approvals.
Delhi High Court sets aside income tax notices against Neeraj Bharadwaj, ruling assessments under Section 153C require incriminating material relevant to specific assessment years.
ITAT Hyderabad held that addition under section 69 of the Income Tax Act towards unexplained investment sustained since documents seized is incriminating in nature. Accordingly, appeal of assessee dismissed.
Kerala High Court held that section 245C doesn’t prescribed any prior cut-off date for filing settlement application. Unadjudicated notice u/s. 153A/ 153C as on the date of application is the only requirement.
ITAT Delhi held that granting of single approval under section 153D of the Income Tax Act for difference assessment years and that too mechanically without application of mind is not sustainable. Accordingly, entire proceedings initiated u/s. 153C quashed.
