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Section 153C

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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


Reassessment Quashed for Addition Based on Retracted Search Statements & missing DIN

October 30, 2025 843 Views 0 comment Print

Mumbai ITAT deleted a ₹4.20 lakh addition, quashing the reassessment because the addition was based solely on uncorroborated, retracted search statements and “dumb documents.” The tribunal ruled that once retracted, statements lose evidentiary value without independent verification.

Addition u/s. 68 quashed as evidences establishing identity, creditworthiness and genuineness not invalidated

October 30, 2025 825 Views 0 comment Print

ITAT Raipur held that addition u/s. 68 of the Income Tax Act made without invalidating evidences establishing identity/ creditworthiness of investor and genuineness of transaction not justifiable. Accordingly, appeal of revenue dismissed.

Bombay HC Voids Income Tax Case Transfer Post-Assessment Completion

October 29, 2025 720 Views 0 comment Print

Bombay High Court quashed the Section 127 transfer of a former CFO’s case from Mumbai to Delhi, ruling that the basis for transfer coordinated investigation eased once the main company’s assessment was complete.

ITAT Delhi Quashes Additions Beyond Six-Year Limit Under Section 153C

October 29, 2025 573 Views 0 comment Print

Tribunal upheld CIT(A)’s view that assessments for AYs 2013-14 to 2015-16 fell outside permissible six-year block under Section 153C. Additions made by AO were held time-barred and without jurisdiction.

Search Assessment Barred: Limitation Period Starts When AO Gets Seized Papers

October 29, 2025 711 Views 0 comment Print

ITAT Delhi dismissed the Revenue’s appeal, ruling that the assessment under Section 153C was time-barred because the block period must be calculated from the date the Assessing Officer (AO) of the non-searched person received the seized material. The ruling confirms that the date of the original search is irrelevant for non-searched persons.

ITAT Delhi Holds Assessment Beyond Six-Year Limit Invalid Under Section 153C

October 29, 2025 594 Views 0 comment Print

ITAT upheld CIT(A)’s order deleting additions for AY 2013–14, ruling that year fell outside six-year block under Section 153C based on satisfaction date in FY 2021–22.

ITAT Pune Upholds Additions on Demonetisation Cash & GP Estimation – Liquor Trader’s Appeal Dismissed

October 28, 2025 606 Views 0 comment Print

The Tribunal sustained the addition due to the AO’s rejection of the books under s.145, which was warranted by the assessee’s non-submission of separate purchase/sale and MRP details for country liquor and IMFL. The ITAT found the 10 estimated GP rate reasonable, falling within the normal range for the liquor trade, and confirmed the addition.

Section 153C: Block Period to Be Counted from Date of Material Receipt, Not Date of Search

October 28, 2025 786 Views 0 comment Print

The dispute was the computation of the block period under S 153 for a non-searched person, where the AO counted the period from the search date. The ITAT affirmed the quashing of the assessment, ruling that the block period must be reckoned from the date the seized material is received by the jurisdictional AO, as per binding Supreme Court precedent.

Common 153D Approval for 14 Years Held Void – ITAT Quashes Entire Block of Assessments

October 26, 2025 690 Views 0 comment Print

Delhi ITAT ruled that a single, non-speaking approval u/s 153D issued for 14 assessment years and two assessees was invalid, holding that approval must be year-specific and assessee-specific. All assessments were quashed as void ab initio.

ITAT Delhi Quashes Reassessment – Borrowed Satisfaction from Investigation Wing Held Invalid

October 26, 2025 645 Views 0 comment Print

The Delhi ITAT invalidated a reassessment, ruling the AO failed to establish independent ‘reason to believe’ and merely borrowed satisfaction from an Investigation Wing report without tangible material or a live link to the assessee’s income. This judgment establishes that reassessment cannot be based solely on second-hand, non-incriminating information from a third-party search.

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