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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 372 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


Section 68 Addition Invalid if Assessee Proves Genuineness of Unsecured Loans: ITAT Mumbai

March 17, 2025 1269 Views 0 comment Print

In pursuance of search, notice u/s.153A was issued and in response, assessee also filed its return of income. AO noted that assessee had taken loan from four parties during the years under consideration.

Time-barred Section 148 – Finance Act, 2021: Rajasthan HC Stays Final Order

March 14, 2025 1464 Views 0 comment Print

 Rajasthan High Court stays final order in Radha Mohan Maheshwari’s reassessment case, citing time-barred notice under Section 148. Proceedings may continue, pending reply.

 Rajasthan HC Stays Final Order in Time-Barred Reassessment

March 14, 2025 1101 Views 0 comment Print

 Rajasthan High Court stays final order in Ram Babu Agarwal’s reassessment case, citing time-barred notice under Section 148. Proceedings may continue, pending reply.

Initiation of reassessment u/s. 147 based on search action instead of 153A/153C is untenable

March 11, 2025 1878 Views 0 comment Print

Bombay High Court held that once search action u/s. 132 of the Income Tax Act is the foundation of the case, assessment could be initiated only under section 153A/ 153C. Thus, initiation of reassessment proceedings u/s. 147 is liable to be quashed.

Proceedings u/s. 153C cannot be triggered without formation of opinion by AO of non-searched person

March 10, 2025 972 Views 0 comment Print

Delhi High Court held that Section 153C as application at relevant time didn’t contemplate two tier recordal of satisfaction. Thus, proceedings u/s. 153C couldn’t have been triggered mechanically without formation of opinion by AO of non-searched person.

No addition u/s 69B as seized quantity of jewellery was under the Limit prescribed by Circular No. 1916

March 10, 2025 1002 Views 0 comment Print

It was held that considering the provisions of CBDT Circular No. 1916 and the explanation provided by the assessee, the seized gold jewellery up to the specified thresholds for each family member should be treated as explained.

Rajasthan HC Orders 20% Deposit for Stay in Reassessment Case

March 8, 2025 708 Views 0 comment Print

 Rajasthan HC allows partial relief in reassessment dispute, directing a 20% deposit for stay on demand recovery while cases await further hearing.

Search Incriminating Material Requires Proceedings Under Section 153C, Not 147/148

March 8, 2025 1347 Views 0 comment Print

ITAT Jaipur rules that when search finds incriminating material, proceedings must be under Section 153C, not 147/148. Read case details of DCIT vs. Kailash Chand Hirawat.

Section 292C’s presumption applies only to person from whom documents seized

March 6, 2025 1983 Views 0 comment Print

ITAT Delhi deletes additions against Sanmati Jewellers due to lack of corroborative evidence and delay in 153C proceedings. Read key observations and case laws.

Addition u/s. 69 without any concrete evidence against assessee is not sustainable

March 4, 2025 1062 Views 0 comment Print

ITAT Mumbai held that addition under section 69 towards unexplained cash made by the AO without bringing any concrete evidence on record incriminating the assessee is not sustainable. Accordingly, addition u/s. 69 deleted.

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