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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


Assessment under section 153 without opportunity of hearing to Assessee is invalid

March 28, 2023 1911 Views 0 comment Print

Manishkumar Tulsidas Kaneriya Vs ACIT (Gujarat High Court) Section 144,  contemplates providing the assessee an opportunity of being heard before making assessment. The First Proviso mentions that such opportunity shall be given by the assessing officer by serving notice to the assessee, mentioning date and time for completion of the assessment to the best of […]

Addition based on documents found at separate search at another person under 153A unsustainable

March 27, 2023 3384 Views 0 comment Print

ITAT Delhi held that addition is made on the basis of documents found from the separate search at another person. Accordingly, assessment should have been done under section 153C of the Income Tax Act and not under section 153A of the Income Tax Act.

No addition/ disallowance u/s 153C without incriminating material found during third person search

March 25, 2023 3333 Views 0 comment Print

ITAT Mumbai held that no additions or disallowances can be made u/s. 153C of the Income Tax Act in absence of any incriminating material found during the search on a third person.

In absence of any incriminating documents seized during search- Additions not justified

March 14, 2023 3837 Views 0 comment Print

In absence of any incriminating documents seized during search, AO is not justified in making addition in non-abated assessment orders u/S 153-A r/W Sec 143(3) of Income Tax Act of 1961.

Addition for Unexplained Jewellery – ITAT grants relief considering Status & Traditional Practices

March 13, 2023 615 Views 0 comment Print

Mohamed Mohideen Ayesha Nasreen Vs ACIT (ITAT Chennai) ITAT held that it could be seen that assessee is living with her husband and three children (Two daughters and one son) in USA. She has got married in the year 2003. In this letter, the assessee has submitted that approx. 1201 grams of jewellery belong to […]

Section 153C Assessments based on Invalid Notices are liable to be quashed

March 12, 2023 5277 Views 0 comment Print

Malik Network & Computer P. Ltd. Vs ITO (ITAT Delhi) One of the controversies in the present case arises towards computation of limitation period under Section 153C of the Act for the purposes of issuance of notice and assessment thereon. As per Section 153A of the Act (in the case of searched persons), the limitation […]

On-money receipts taxable as unaccounted sales only to the extent of net profit rate

February 28, 2023 3774 Views 0 comment Print

ITAT Ahmedabad held that entire receipts on account of on-money-premium charged would not to be treated as the undisclosed income but only net profit rate could be applied on unaccounted sales/receipt for the purpose of making addition.

Tax authorities must follow proper procedures for handling & preserving electronic data

February 23, 2023 2088 Views 0 comment Print

Explore the Supreme Courts insights on Section 153C of the Income Tax Act, emphasizing due process. Learn key takeaways, including scope, applicability, assessment timelines, and the burden of proof. Ensure proper handling of electronic data in tax authority procedures.

Initiation of proceedings u/s 153C based on documents impounded during survey u/s 133A is bad in law

February 14, 2023 2196 Views 0 comment Print

ITAT Mumbai held that initiation of proceedings under section 153C of the Income Tax Act based on documents impounded during the course of survey under section 133A of the Income Tax Act is bad in law and unjustified as no such material were found during the course of search.

Budget 2023 aligns timeline under section 153 of Income Tax Act

February 5, 2023 19044 Views 0 comment Print

Budget 2023 aligns timeline under section 153 of Income Tax Act. Learn more about the 2016 Finance Acts reduced assessment order period of 9 months for 2021-22 and later assessment years.

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