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Section 153C

Latest Articles


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 1566 Views 0 comment Print

FAQs on Compounding of Offences under Income Tax Act, 1961

Income Tax : CBDT issues new compounding guidelines simplifying process, eligibility, charges, and procedures under the Income-tax Act from Oct...

October 30, 2025 1968 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 2940 Views 0 comment Print

Time-Barred Assessment under Section 153C: Judicial Precedents

Income Tax : AY 2015-16 assessment under Section 153C held time-barred. Judicial rulings confirm six-year limit runs from handing over of seize...

September 5, 2025 2718 Views 0 comment Print

Consolidated Satisfaction Note under Section 153C Held Invalid

Income Tax : Learn why a consolidated satisfaction note for multiple assessment years is legally invalid under Section 153C of the Income Tax A...

September 5, 2025 1764 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 2127 Views 0 comment Print


Latest Judiciary


Section 153C Assessment Quashed Over Unsigned Seized Document: ITAT Hyderabad

Income Tax : The Tribunal held that an unsigned agreement without corroboration cannot be treated as incriminating material. Proceedings under ...

April 18, 2026 72 Views 0 comment Print

On-Money Addition Based on Excel Sheet Deleted: No Corroborative Evidence

Income Tax : The Tribunal deleted additions where the Revenue failed to prove actual cash transactions. It emphasized that suspicion and assump...

April 18, 2026 192 Views 0 comment Print

Reassessment Quashed as Wrong Provision Invoked Instead of Section 153C: ITAT Jaipur

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...

April 17, 2026 450 Views 0 comment Print

Reopening Fails on Both Counts: Invalid Sec 148A Notice and Time-Barred Sec 148 Render Assessment Void

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...

April 16, 2026 171 Views 0 comment Print

Bombay HC Quashed Section 153C Proceedings Due to Delay in Recording Satisfaction Note

Income Tax : The Court held that a 21-month delay in recording the satisfaction note violates the requirement of immediacy. It ruled that such ...

April 15, 2026 201 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 71211 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 2466 Views 0 comment Print


Section 40A(3) cannot be invoked as income estimated based on gross profit rate

July 1, 2025 609 Views 0 comment Print

ITAT Delhi held that invocation of provisions of section 40A(3) of the Income Tax Act not justifiable as income is estimated on the basis of gross profit rate. Thus, disallowance u/s. 40A(3) set aside and appeal stands allowed.

ITAT Delhi Deletes On-Money Addition for Misapplication of Section 153C

June 25, 2025 375 Views 0 comment Print

Delhi ITAT sets aside ₹42.94 lakh tax additions, ruling Section 153C incorrectly applied. Seized documents must “pertain” not “belong,” and Section 292C presumption doesn’t extend to third parties.

Seized Documents Receipt Date by AO Determines Limitation for Section 153C Notice

June 24, 2025 432 Views 0 comment Print

Madras High Court held that period of limitation for issuing notice under section 153C of the Income Tax Act to person other than searched person shall be date of receiving books of accounts or documents seized by AO having jurisdiction over such other person.

Transaction Genuine under section 68 if Loan Repaid with Interest: ITAT Delhi

June 24, 2025 1878 Views 0 comment Print

By returning the loan, the assessee has only utilised the loan for the purpose of business and repaid the same. Merely because some operator has managed the affairs and all the transactions cannot be labelled as non-genuine.

Income Tax Appeal Dismissed for Non-Prosecution Remanded for Fresh Adjudication

June 21, 2025 330 Views 0 comment Print

Mumbai ITAT remands Shankarlal Shantilal Mali’s appeal on unexplained cash deposits of over 1 crore for AY 2014-15 to CIT(A) for fresh adjudication.

Section 153C Amendment not applicable to searches before June 1, 2015: SC

June 19, 2025 678 Views 0 comment Print

Supreme Court rules 2015 amendment to Income Tax Act’s Section 153C, broadening third-party assessment, is not retrospective; applies only to searches after June 1, 2015.

Six-Year Tax Assessment for Third Parties Begins on AO’s Receipt of Seized Materials: SC

June 19, 2025 879 Views 0 comment Print

The Supreme Court clarifies that the six-year tax assessment period for third parties, whose documents are seized, starts from the date their AO receives materials, not the original search date.

Assessment order passed u/s. 153C quashed as barred by limitation: ITAT Delhi

June 18, 2025 702 Views 0 comment Print

ITAT Delhi held that assessment order passed by AO under section 153C read with section 143(3) of the Income Tax Act is passed beyond prescribed time limited. Hence, the order barred by limitation is liable to be quashed.

Income Tax Transfer order u/s. 127 quashed due to procedural lapses: Madras HC

June 17, 2025 672 Views 0 comment Print

Madras High Court held that transfer order under section 127 of the Income Tax Act is legally untenable on account of various procedural lapses. Hence, the transfer order is quashed and matter is remanded bank for passing fresh orders on merits.

ITAT Invalidates Section 153C Invocation: Distinction Between “Belonging” & “Pertaining/Relating” Proved Crucial

June 17, 2025 2550 Views 0 comment Print

Delhi ITAT sets aside tax additions against a couple, ruling Section 153C satisfaction invalid and emphasizing the belongs to vs. pertains to distinction.

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