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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 1557 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


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 96 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 153 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 174 Views 0 comment Print

No reassessment beyond 3 years without proper sanction of prescribed higher authority

Income Tax : Reassessment proceedings was invalid for a notice issued beyond three years without the sanction of the prescribed higher authorit...

April 15, 2026 240 Views 0 comment Print

ITAT Rajkot: Addition Based on ‘Dump Excel Sheet’ Deleted – No Evidence, No Tax

Income Tax : The Tribunal held that unsigned excel sheets without supporting evidence cannot justify additions. It ruled that absence of corrob...

April 14, 2026 672 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


Reopening of assessment merely based on change of opinion is unsustainable

October 6, 2023 1719 Views 0 comment Print

Bombay High Court held that re-opening of assessment under section 148 of the Income Tax Act, without indicating basis for having a reason to belief that income has escaped assessment, merely based on change of opinion is unsustainable in law and liable to be quashed.

‘Non-cooperative attitude’ alone cannot justify penalties: ITAT Delhi

October 2, 2023 1029 Views 0 comment Print

Explore the case of Alankit Imaginations Ltd vs. DCIT (ITAT Delhi), where penalties were challenged. Learn why a ‘non-cooperative attitude’ alone cannot justify penalties.

Order framed u/s 153C without incriminating material found during search is unsustainable

September 27, 2023 2046 Views 0 comment Print

ITAT Delhi held that the additions/disallowance, devoid of any incriminating material found during the course of search, cannot validate the assessment orders framed u/s 153C of the Act. Accordingly, assessment orders u/s 153C cannot be sustained and liable to be quashed.

Acquiring jurisdiction u/s 153C without satisfaction note is unsustainable in law

September 20, 2023 2244 Views 0 comment Print

ITAT Chennai held that acquiring jurisdiction u/s 153C of the Income Tax Act without fulfilling the requirement of satisfaction note in case of searched person is unsustainable and liable to be quashed.

Reassessment proceeding based on other officer’s information without cogent material unjustified

September 16, 2023 1284 Views 0 comment Print

ITAT Delhi held that initiation of reassessment proceedings u/s 147 of the Income Tax Act merely on the basis of information from other officer without cogent and demonstrable material unjustified.

AO doesn’t have jurisdiction to assess/re-assess unabated assessment u/s. 153C without any incriminating material

September 14, 2023 2139 Views 0 comment Print

Bombay High Court held that jurisdiction to assess/ reassess u/s 153C of the Income Tax Act in respect of unabated/ completed assessments without any incriminating material found during the search unjustified.

Taxing Agricultural Income Under Section 153C: Role of Incriminating Material

September 14, 2023 666 Views 0 comment Print

Exploring the key takeaways from the ITAT Chennai ruling in Duraisamy Parameswaran Vs ACIT, focusing on how agricultural income is treated under Section 68 of the Income Tax Act.

Section 263 Revision Sustained as AO not examined Seized Documents

September 13, 2023 738 Views 0 comment Print

ITAT Chennai held that assessment order passed without examining the seized documents is prejudicial to the interest of revenue and hence the revisionary order passed under section 263 of the Income Tax Act duly sustainable.

Addition u/s 69C based on dumb document is unsustainable

September 11, 2023 2112 Views 0 comment Print

ITAT Delhi held that addition under section 69C of the Income Tax Act towards unexplained expenditure based on dumb documents not sustainable in law.

Section 153A: No Addition Without Incriminating Evidence in Unabated Assessment

September 9, 2023 1764 Views 0 comment Print

ITAT Chennai in Estate of Late Smt. Jayanthi Krishnamurthy Vs ACIT held that no addition could be made under section 153A in absence of incriminating evidence resulting from a search, especially if assessment is unabated.

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