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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 81 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 171 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 2460 Views 0 comment Print


Cost of improvement & indexation cannot be claimed without evidence to prove construction

April 28, 2023 32508 Views 0 comment Print

Assessees could not claim cost of improvement and indexation cost as assessee had to furnish some evidence and in the absence of any evidence or information, the information contained in the registered sale deed was required to be accepted.

Address to deliver Income Tax notice in case of person in judicial custody

April 28, 2023 2007 Views 0 comment Print

PCIT Vs Narayan Kumar Khaitan (Orissa High Court) Case Law on Service of notice required through Superintendent of Jail if assessee is in judicial custody. A search and seizure operation under section 132 was conducted on SM and group wherein certain incriminating documents were found. Subsequently, assessment in case of assessee was completed under section […]

Completed/Unabated Assessments – No Addition if no Incriminating Material Found During Search: SC

April 25, 2023 4641 Views 0 comment Print

Core issue involved in the appeals is the scope of assessment u/s 153A. question posed for consideration is, as to whether in respect of completed assessments/unabated assessments, whether the jurisdiction of AO to make assessment is confined to incriminating material found during the course of search u/s 132 or requisition u/s 132A or not,

Section 153C proceeding covers six A.Y. immediately preceding A.Y. in which search is conducted

April 25, 2023 1959 Views 0 comment Print

ITAT Delhi held that as per amendment to section 153C of the Income Tax Act the six assessment years immediately preceding the AY relevant to the previous year in which search is conducted or requisition is made will come into the purview of block assessment years.

No addition in case of search Assessment, if no incriminating material found during search: SC

April 25, 2023 15030 Views 0 comment Print

In respect of completed/unabated assessments, no addition can be made in absence of any incriminating material found during search: SC

Proceedings u/s 153C invocable only when AO proves that material seized from third party belongs to assessee

April 22, 2023 2244 Views 0 comment Print

ITAT Ahmedabad held that invocation of proceedings u/s 153C of the Income Tax Act unsustainable as AO has not put on record that material seized during the course of third party search belongs to the assessee.

Section 153C Notice invalid if not grants Opportunity to Assessee for filing Objection

April 22, 2023 1599 Views 0 comment Print

HC held that with respect to objections & satisfaction note, AO will pass a speaking order; copies of which will be furnished to petitioner

Amendment to section 153C also applies to Section 132 searches conducted before 01.06.2015: SC

April 8, 2023 2070 Views 0 comment Print

SC held that amendment to Section 153C vide Finance Act, 2015 shall be applicable to searches conducted under Section 132 before 01.06.2015

Approval granted under section 153D on ‘presumption’ basis is invalid

March 31, 2023 4674 Views 0 comment Print

Akshata Realtors Pvt. Ltd. Vs ACIT (ITAT Raipur) ITAT held that the Approval granted by the JCIT, Range Central, Raipur under section 153D on ‘presumption’ basis without thoroughly going through the seized material, assessment records etc. as perfunctory, without application of mind, mechanical in nature hence, invalid, bad in law and liable to be quashed. […]

One appeal cannot be filed against two reassessment orders for same assessment year-

March 29, 2023 1812 Views 0 comment Print

ACIT Vs Ajit Anantrao Pawar (ITAT Mumbai)  The facts stated hereinabove by the ld. AR are not in dispute with regard to framing of two independent section 153C assessments for each assessment year. It is not in dispute that six independent appeals were filed by the assessee before the ld CIT(A) and accordingly, numbered thereon […]

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