Income Tax : Judicial rulings clarify that satisfaction for initiating action against other persons in search cases must be recorded promptly. ...
Income Tax : CBDT issues new compounding guidelines simplifying process, eligibility, charges, and procedures under the Income-tax Act from Oct...
Income Tax : CBDT's new Compounding of Offence Guidelines (2024) simplify the process but maintain strict compliance rules. Learn about eligibi...
Income Tax : AY 2015-16 assessment under Section 153C held time-barred. Judicial rulings confirm six-year limit runs from handing over of seize...
Income Tax : Learn why a consolidated satisfaction note for multiple assessment years is legally invalid under Section 153C of the Income Tax A...
Income Tax : Learn about the new block assessment provisions for cases involving searches under section 132 and requisitions under section 132A...
Income Tax : The Tribunal held that an unsigned agreement without corroboration cannot be treated as incriminating material. Proceedings under ...
Income Tax : The Tribunal deleted additions where the Revenue failed to prove actual cash transactions. It emphasized that suspicion and assump...
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...
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...
Income Tax : The Court held that a 21-month delay in recording the satisfaction note violates the requirement of immediacy. It ruled that such ...
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...
Delhi HC dismisses PCIT appeal in Karina Airlines case, ruling amendments to Section 153C of the IT Act do not apply retroactively to pre-2017 searches.
Delhi High Court held that ITAT cannot address the ground which remained unaddressed by CIT(A). Accordingly, matter restored back to CIT(A) to decide on the grounds that were not decided.
ITAT Delhi held that orders passed based on illegal assumption of jurisdiction on the basis of satisfaction note which was recorded without application of mind and quite in a mechanical manner is liable to be set aside. Accordingly, addition deleted.
ITAT Delhi held that merely seizure of share certificate cannot be considered as incriminating material on its own unless other corroborative evidence are found during the search. Accordingly, appeal of the department dismissed.
Delhi High Court held that uploading of information by the investigation wing of the Income Tax department would not be a substitute for recording of a satisfaction note by the AO of searched person for handing over material to AO of person other than searched person.
‘Gupt Daan’,a secret gift regarding unexplained cash in a Religious Trust locker was pertaining to RNB Temple Trust and was already brought on record to the extent of Rs.1,79,00,000/- which was evident from the Balance Sheet submitted.
Search action was carried out on residential premises of assessee. Several incriminating documents were found and seized. Assessee was issued with notice to file Income Tax Return and seeking details for seven assessment years within 5 days.
Among the documents seized contained information pertaining to the Assessee and AO recorded his satisfaction that those documents have bearing on the determination of total income of the Assessee.
Assessee claimed to have submitted details / documents / explanation as required by AO for the purpose of assessment in the case of assessee under section 143(3) during the course of assessment proceedings.
The company contended that the satisfaction note required to initiate the assessment under section 153C was recorded by AO only on January 18, 2021, making the search year AY 2021-22.
