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...
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.
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 […]
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,
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.
In respect of completed/unabated assessments, no addition can be made in absence of any incriminating material found during search: SC
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.
HC held that with respect to objections & satisfaction note, AO will pass a speaking order; copies of which will be furnished to petitioner
SC held that amendment to Section 153C vide Finance Act, 2015 shall be applicable to searches conducted under Section 132 before 01.06.2015
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. […]
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 […]