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 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 : Reassessment proceedings was invalid for a notice issued beyond three years without the sanction of the prescribed higher authorit...
Income Tax : The Tribunal held that unsigned excel sheets without supporting evidence cannot justify additions. It ruled that absence of corrob...
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...
ITAT Mumbai held that change of opinion is not permissible under the garb of reopening of assessment under section 147/148 of the Income Tax Act.
ITAT Amritsar held that initiation of Assessment Proceedings u/s 153C, instead of section 153A, in case of the searched assessee makes the entire assessment invalid. Accordingly, penalty levied u/s 271(1)(c) is not maintainable.
ITAT Mumbai held that in case of company is involved in providing illicit LTCG/ short term capital loss (accommodation entries), a substantial addition has to be made in the hands of beneficiaries and only a protective assessment can be made in the hands of company providing such accommodation entries.
ITAT Mumbai held that reopening of assessment under section 147 of the Income Tax Act based on information received by AO from DDIT (investigation) justified subject to fulfilment of conditions as envisaged u/s 147/148.
ITAT Mumbai held that addition towards unexplained and undisclosed income sustained as assessee itself claim payment of cash in the civil suit and failed to explain the source of the cash payment.
In present facts of the case, the Tribunal held that Assessment Order issued without DIN is null and void as it is in violation of CBDT Circular No. 19/2019 dated 1 4th August, 2019.
ITAT Delhi held that initiation of proceedings u/s 153C of the Income Tax Act based on seized dumb documents found in the premises of third party is unsustainable in law as the seized documents are merely loose sheets not forming part of the books of account of the assessee and that they do not constitute admissible evidence.
Analysis of the ITAT Lucknow case Mahendra Lalka Vs DCIT on Sec 69 of the Income Tax Act. Key findings, implications, and legal insights included.
ITAT Jaipur held that in absence of a valid satisfaction note the notice issued under Section 153C of the Income Tax Act 1961 is bad in law. Resultantly the assessment order passed u/s 143(3) r.w.s. 153C of the Act is void ab initio and liable to be quashed.
ITAT Delhi held that addition based on incriminating material found during the search carried out of ‘some other person’ i.e. third person/ party and assessing the same by invoking provision of section 147 instead of section 153C is unsustainable.
