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...
The High Court held that penalty under Section 271D cannot be levied without the Assessing Officer recording satisfaction regarding violation of Section 269SS. In the absence of such finding in the assessment order, the penalty was set aside.
The Tribunal quashed the reassessment as the notice issued beyond three years failed to satisfy mandatory conditions under Section 149(1)(b). It held that absence of proper jurisdictional facts and compliance rendered the reopening invalid.
Section 69C addition of ₹1.10 crore deleted as pen drive data lacked valid 65B certificate; ITAT Hyderabad held third-party digital evidence inadmissible without corroboration.
The Tribunal clarified that mere search under Section 132 does not automatically justify reopening. The AO must demonstrate year-specific escapement of income and follow mandatory approval procedures.
The Delhi High Court held that notices issued after the satisfaction note date were time-barred. Following earlier precedent, the impugned notices were set aside.
The Tribunal ruled that entries found in a third-party pen drive cannot justify addition without independent corroboration. Failure to allow cross-examination violated principles of natural justice, leading to deletion.
The Tribunal deleted ₹2 lakh cash addition as no incriminating material directly linked the assessee to alleged on-money. Reliance solely on pen drive data and third-party statements without cross-examination was held insufficient.
The Tribunal held that in completed assessments, no addition can be made under Section 153A without incriminating material found during search. The addition under Section 68 was annulled as jurisdiction was invalid.
ITAT Mumbai deleted Sec 69 addition for alleged on-money, holding third-party statements and pen-drive data without cross-examination or corroboration are invalid evidence.
ITAT Bangalore quashed reassessment for AY 2017-18, holding notice issued on 12-04-2024 time-barred under first proviso to Sec.149(1), despite prior 148A proceedings.
