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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 1560 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 2712 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 48 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 48 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 231 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 162 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


Reassessment u/s. 148 based on cryptic reasons and mechanical approval quashed: ITAT Delhi

October 14, 2024 1332 Views 0 comment Print

ITAT Delhi held that the issuance of notice u/s. 148 based on cryptic reasons combined with a mechanical approval of the Pr.CIT u/s. 151 of the Income Tax Act do not pass the test of judicial scrutiny. Thus, reassessment quashed.

Approval granted u/s. 153D in mechanical manner is bad-in-law: ITAT Bangalore

October 4, 2024 1116 Views 0 comment Print

ITAT Bangalore held that approval given under section 153D of the Income Tax Act at the fag end of assessment in a mechanical manner and without application of mind is invalid and bad in law.

Granting opportunity to cross examine essential as addition based on 3rd party statement: ITAT Bangalore

October 2, 2024 1122 Views 0 comment Print

ITAT Bangalore held that granting an opportunity to cross examine essential when addition is made on the basis of 3rd party statements. Non-granting any opportunity of cross examination violates the principle of natural which vitiates the validity of addition.

No Section 270A Penalty on Estimation-Based Disallowances

September 26, 2024 2514 Views 0 comment Print

ITAT held that disallowances based on estimations do not constitute underreporting of income and thus are not grounds for a penalty under Section 270A.

Prior claims against Corporate Debtor stood extinguished consequent to approval of resolution plan under IBC

September 25, 2024 651 Views 0 comment Print

Since upon the completion of Corporate Insolvency Resolution Process (CIRP),  assessee had changed hands and commenced under a new ownership and management, the Bombay High Court held that tax proceedings pertain to period prior to the CIRP, and consequent to the approval of the resolution plan, the tax proceedings stood extinguished.

Tax Liability on Capital Gains Arises in Year of Possession, Not Occupancy Certificate

September 24, 2024 1968 Views 0 comment Print

Liability to capital gains had not arisen in the assessment year 2017-18 as occupancy certificate was received on 01/02/2017 for commercial portion and 17/03/2017 for residential portion but in the assessment year 2018-19 on receipt of possession.

ITAT Quashes Section 115BBE as Income was from Advertising Business Only

September 16, 2024 1842 Views 1 comment Print

The ITAT Jaipur ruled in ACIT vs Naresh Jain, addressing Section 115BBE, unexplained income, and the benefit of telescoping in tax assessments.

Addition based on observation by DCIT without independent inquiry by AO not sustained

September 6, 2024 1962 Views 0 comment Print

ITAT Delhi held that addition towards undisclosed investment in shares and unsecured loans merely based on observation made by DCIT without independent inquiry by AO is unjustified and hence the addition is liable to be deleted.

No tax on amount received as ‘On-Money’ from sale of Flats u/s 68

September 3, 2024 1779 Views 0 comment Print

Since the addition pertained to the “receipt of money” from the sale of flats by the assessee and these amounts did not represent the actual receipts in the hands of the assessee, they could not be subjected to tax.

Assessment order was quashed as search assessment should be computed u/s 153 instead of u/s 147

September 3, 2024 1425 Views 0 comment Print

Since there was no failure on the part of assessee to fully and truthfully disclose material facts therefore, assessment under sections 147-148 was not valid as the specific provisions of Section 153C were deemed to take precedence over the general provisions of Section 147.

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