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Section 153C

Latest Articles


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...

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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...

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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...

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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...

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Budget 2025: Block Assessment Amendments in Income Tax Search Cases

Income Tax : Budget 2025 revises block assessment rules for search cases, covering undisclosed income, assessment procedures, penalties, and ti...

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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...

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Latest Judiciary


Property Deal Addition Fails for Breach of Section 153C Time Limits

Income Tax : Revenue failed to produce a Section 153C satisfaction note showing the date of handing over seized material. ITAT treated the noti...

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Section 153A Assessment Quashed as Notices Issued in Name of Deceased Assessee

Income Tax : The issue was whether an assessment could survive when statutory notices were issued in the name of a deceased person. The Tribuna...

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₹100 Crore U/s 153A Addition Quashed: Seized Third-Party Paper Not Incriminating for Completed Year

Income Tax : ITAT Delhi held that for an unabated year, additions under section 153A require incriminating material. A seized loose sheet and r...

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Section 153C Additions Deleted: No Corroboration for Third-Party Pen-Drive Evidence

Income Tax : The tribunal ruled that statements of third parties cannot be relied upon unless the assessee is provided copies and allowed cross...

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Penalty for Non-Compliance Deleted as Venial Breach Where Assessments Accepted Returned Income

Income Tax : ITAT Mumbai deleted ₹20,000 yearly penalties where assessments under section 153C accepted returned income with no additions, ho...

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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...

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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...

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Section 153C Requirement should be fulfilled by AO before initiating proceedings

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In the given case, the issue under consideration is whether there is a compliance of the provisions of Section 153C of the Act by the Assessing Officer and all the conditions which are required to be fulfilled before initiating the proceedings under Section 153C of the Act have been satisfied or not?

Section 153C notice invalid if separate satisfaction not recorded

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Notice under section 153C was to be issued with recording of separate satisfaction note even if AO of searched person and the other person, i.e., assessee was one and the same,therefore, in absence of the same, any order passed, in pursuance of such notice was void ab-initio and liable to be quashed

Section 153C Assessment not valid for assessment years not covered within 6 year period

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Where the impounded documents had been received by AO on 29-1-2014 and six assessment years under section 153C in case of assessee would be assessment years 2008-09 to 2013-14, therefore, initiation of proceedings under section 153C by AO for assessment years 2006-07 to 2011-12, was illegal and not sustainable in law.

Various Assessments Under The Income Tax Law

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Every taxpayer has to furnish the details of his income to the Income-tax Department. These details are to be furnished by filing up his return of income. Once the return of income is filed up by the taxpayer, the next step is the processing of the return of income by the Income Tax Department. The […]

Section 153C- Statement of others cannot be treated as document of Assessee

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Pr. CIT Vs Dreamcity Buildwell Pvt. Ltd. (Delhi High Court) In the present case, the Revenue is seeking to rely on three documents to justify the assumption of jurisdiction under Section 153 C of the Act against the Assessee. Two of them, viz., the licence issued to the Assessee by the DTCP and the letter […]

Search Assessment under Section 153A & Section 153C

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This article covers some of the basic but important issues faced by the Assessing Officer in Search assessment. It also covers the judicial history of the issue and stand taken by the Department. After completion of search by the Investigation Wing, correct application of the provision of the Income Tax Act and assessment of true income of the assessee is most important task of the A.O. in Central Charge

Bank Account disclosed in ITR found in search cannot be treated as Incriminating Material

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The issue under consideration is whether the addition made by AO u/s 68 by considering the share application money received by assessee as unexplained cash credit is justified in law?

Selection of Case of Search Years in ITBA Assessment module

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Availability of Miscellaneous Functionalities related to ‘Selection of Case of Search Year’ and ‘Relevant Search Years’ in Assessment module of Income Tax Business Application (ITBA)- reg. ITBA – Assessment Instruction No. 12 DIRECTORATE OF INCOME TAX (SYSTEM) ARA Center, Ground Floor, E-2, Jhandewalan Extension, New Delhi – 110055 F.No. System/ITBA/Instruction/Assessment/177/2016-17/ Dated: 12/09/2019 To All Principal […]

Non-recording of satisfaction by AO of searched person while issuing notice to other party makes notice illegal

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AO of the searched person had not rebutted the presumption that the seized documents  belonged to M/s. C Ltd but belonged to other person, i.e, assessee, therefore, issue of notice under section 153C on assessee was illegal. 

AO not justified in assuming jurisdiction u/s 153C based on documents which does not indicate existence of any unaccounted income

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Impugned bank certificate is not an incriminating document based on which the concluded assessment in the case of the assessee can be disturbed. In view of this according to us , we hold that no addition can be made in the hands of the assessee in absence of any incriminating evidence leading to any unaccounted income unearthed during the course of search. 

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