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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 90 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 150 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


Section 153C: ITAT Delhi dismisses Revenue’s Appeal due to Lack of Jurisdiction

June 13, 2023 798 Views 1 comment Print

The ITAT Delhi has dismissed the Revenue’s appeal in the case of ACIT vs. Cogent Realtors Pvt. Ltd. The appeal was dismissed based on the lack of jurisdiction under Section 153C of the Income Tax Act due to the absence of incriminating material. The disallowance made by the Assessing Officer was also found to be unsustainable.

Section 153C Addition not Sustainable without Incriminating Material: ITAT Delhi

June 11, 2023 846 Views 0 comment Print

ITAT Delhi has ruled that additions made under Section 153C of Income Tax Act cannot be sustained without any incriminating material found during a search and seizure operation.

Case can be transferred from Jurisdictional AO to Central Circle u/s 127

June 6, 2023 8805 Views 0 comment Print

Delhi High Court held that case can duly be transferred from Jurisdictional Assessing Officer to Central Circle by way of passing order under section 127 of the Income Tax Act.

Addition based on some dummy name without incriminating material is unjustified

May 29, 2023 1212 Views 0 comment Print

ITAT Delhi held that addition based on some dummy name without incriminating material reflecting name of the assessee is unjustified.

Penalty order passed in the name of death person after death is invalid

May 21, 2023 8952 Views 0 comment Print

ITAT Bangalore held that any proceedings taken against the deceased before his death shall be deemed to have been taken against the legal representative. However, penalty order passed in the name of death person after his death is invalid.

Order passed on non-existing entity is liable to be quashed

May 18, 2023 1551 Views 0 comment Print

ITAT Delhi held that assessment order passed on non-existing entity (dissolved company) is liable to be quashed as the Assessing Officer has the knowledge of the dissolution of the company.

Third party statement recorded u/s 132(4) not an incriminating document for addition u/s 153A

May 17, 2023 8640 Views 0 comment Print

ITAT Hyderabad held that statement of a third party already recorded u/s 132(4) of the Income Tax Act cannot be considered as an incriminating document for the purpose of making the addition u/s 153A of the Income Tax Act.

Assessment u/s 153C beyond six assessment year is without jurisdiction

May 15, 2023 894 Views 0 comment Print

ITAT Mumbai held that the assessment made u/s 153C of the Income Tax Act beyond the six assessment year is without jurisdiction and liable to be quashed.

Mere Interest waiver will not Vitiate Genuineness of Loan Transaction

May 9, 2023 810 Views 0 comment Print

Merely the parties agreed to not to charge/pay interest on loan will not vitiate the genuineness of such loan transaction unless and until the revenue brought some cogent material on record to prove that such transaction of loan is not genuine.

No assessment under section 153C in absence of incriminating material: SC

May 8, 2023 6678 Views 0 comment Print

DCIT Vs U.K. Paints (Overseas) Ltd. (Supreme Court of India) As found by the High Court in none of the cases any incriminating material was found during the search either from the Assessee or from third party. In that view of the matter, as such, the assessments under Section 153-C of the Act are rightly […]

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