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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 180 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 393 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 71205 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


Charitable Trust Granted Another Hearing by ITAT Patna on Penalty Dispute

June 17, 2025 267 Views 0 comment Print

Patna ITAT remands penalty case of Narayani Educational Health and Charitable Trust, allowing re-examination of Section 271(1)(b) levy due to lack of evidence submission.

Proceedings u/s. 153A bad-in-law as no certificate issued as per rule 112F: ITAT Mumbai

June 16, 2025 558 Views 0 comment Print

ITAT Mumbai held that proceedings u/s. 153A of the Income Tax Act is bad in law since case falls within parameters of rule 112F r.w. third proviso to section 153A, however, no certificate was issued by investigating officer even when cash was found during election period.

Pen drive with FY 2014-15 data cannot justify reassessment for AY 2019-20

June 14, 2025 5121 Views 0 comment Print

Delhi High Court quashes Income Tax notice, ruling a pen drive with FY 2014-15 data cannot justify reassessment for AY 2019-20.

Addition u/s 153A for completed assessments couldn’t be made without incriminating material

June 10, 2025 960 Views 0 comment Print

Since the assessments were completed in the case of assesee and there was no incriminating material found during the search in the case of the assessee, the additions made under Section 153A were unsustainable.

Mere custody of funds by Director not Deemed Dividend u/s 2(22)(e) 

June 9, 2025 798 Views 0 comment Print

ITAT Bangalore rules that a director’s mere custody of company funds, without personal use or formal loan, does not constitute a deemed dividend under Section 2(22)(e) of the Income-tax Act.

Reassessment set aside as objections not dealt in accordance with GKN Driveshafts principle

June 4, 2025 618 Views 0 comment Print

Madras High Court held that in re-assessment proceedings the objections of assessee should be dealt in accordance with GKN Driveshafts principle. Here, all the proceedings are set aside since the GKN Driveshafts principle has not been strictly adhered to.

Bogus LTCG Addition Set Aside Due to Lack of Tangible Evidence: ITAT Ahmedabad

June 4, 2025 783 Views 0 comment Print

ITAT Ahmedabad held that addition towards accommodation entries of bogus LTCG cannot be sustained in absence of any iota of tangible perceptible evidence. Accordingly, appeal allowed and addition set aside.

Unexplained credits routed through conduit to be taxed in hands of ultimate beneficiary

June 2, 2025 696 Views 0 comment Print

Delhi High Court held that addition towards unexplained credits against companies used as a conduit for routing accommodation entries is not justified since they are not ultimate beneficiaries. Accordingly, appeal of revenue dismissed.

Section 153C Limitation starts from Date AO receives Documents: Delhi HC

May 20, 2025 678 Views 0 comment Print

Delhi High Court rules that the limitation period under Section 153C of the Income Tax Act begins from the date the Assessing Officer receives the seized documents, quashing an assessment notice for AY 2015-16.

Challenge against order u/s. 153C dismissed due to existence of alternative remedy

May 17, 2025 699 Views 0 comment Print

Madras High Court held that writ against assessment orders issued under section 153C of the Income Tax Act is dismissed existence of alternative remedy. Accordingly, writ petition dismissed and petitioner directed to approach the appellate authority.

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