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...
Approval under Section 153D was invalid, as it was granted mechanically and collectively for several years, without independent application of mind. Such perfunctory approval defeats the statutory safeguard intended by the legislature. Consequently, the entire proceedings and assessments were quashed.
Relying on binding Supreme Court and High Court precedents, the Tribunal set aside the revisionary order as legally invalid because the PCIT failed to bring the legal heir on record before passing the order. The ruling firmly establishes that an income tax order passed against a dead person is a nullity and cannot be enforced.
ITAT Chandigarh deletes ₹1.12 Cr addition for Northern Royalty Co. u/s 153C. Assessee’s revised profit (14-15%) was far higher than the 1.47% profit indicated by seized mining records. Arbitrary 18% NP rate rejected; consistency upheld. Revised return accepted.
ITAT Hyderabad sustains unexplained investment based on a builder’s seized document with matching sale details but deletes gift addition, citing the Revenue’s failure to disprove the donor’s capacity.
ITAT Chennai quashes assessment because the notice u/s 143(2) was issued by a non-jurisdictional AO after jurisdiction transfer u/s 127 was effective. Jurisdictional error is fatal; entire assessment declared void ab initio.
The Karnataka High Court ruled that when reassessment is based solely on material seized from a third-party search, the Income Tax Department must follow the specific procedure under Section 153C of the IT Act, not the general Section 147.
Delhi High Court rules ITSC applications filed until March 31, 2021, are valid and must be treated as pending. Retrospective cut-off of February 1, 2021, is arbitrary, violating Article 14.
Delhi High Court rules that a Section 153C notice for AY 2010-11 was time-barred. Citing the RRJ Securities Ltd. precedent, the Court confirms the six-year block period for an “other person” must be calculated from the date documents are handed over to the AO, not the date of the original search.
Hyderabad ITAT quashes ₹20.50 lakh tax addition based on medical college search documents. Rules third-party material needs corroboration and cross-examination.
ITAT Delhi held that regular assessment order passed under section 143(3) of the Income Tax Act without aid of section 153C despite satisfaction note from AO of searched person is not supportable in law. Thus, assessment framed u/s. 143(3) is void ab-initio.
