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 an unsigned agreement without corroboration cannot be treated as incriminating material. Proceedings under ...
Income Tax : The Tribunal deleted additions where the Revenue failed to prove actual cash transactions. It emphasized that suspicion and assump...
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 : 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...
The Tribunal held that without any incriminating material belonging to the assessee found during search, proceedings under Section 153C are invalid. Addition based solely on third-party statements was set aside.
Holding that the Assessing Officer recorded a mechanical satisfaction note without concrete incriminating evidence, the Tribunal dismissed the Revenues appeals and confirmed invalid jurisdiction under Section 153C.
ITAT held that a portion of cash paid could reasonably be sourced from accumulated withdrawals from joint bank accounts. The remaining unexplained amount was reduced on an estimated basis.
The Tribunal held that assumption of jurisdiction under Section 153C was invalid due to a defective and consolidated satisfaction note. As the mandatory requirement of year-wise satisfaction was not met, the entire assessment was quashed.
The Tribunal held that acceptance of returned income without examining material indicating possible unaccounted cash investment amounts to lack of inquiry. Section 263 revision was therefore lawfully sustained.
The ITAT held that approval under Section 151 was invalid as the PCIT merely noted As per Annexure without independent satisfaction. The reassessment under Section 147 was declared void ab initio.
The Tribunal noted that the subject line of the approval letter excluded the concerned assessment year, evidencing lack of scrutiny. It held that such defective approval invalidates the assessment.
ITAT ruled that reliance on statements without offering cross-examination and without supporting evidence violates principles of natural justice. Additions under Sections 69A and 153C were set aside.
The Tribunal held that mere booking of flats and receipt of token advances do not justify revenue recognition under the Percentage Completion Method without legally enforceable agreements.
The Tribunal held that once satisfaction is recorded under Section 153C, assessment for covered years must proceed strictly under that provision. Framing assessment under Section 143(3) was declared jurisdictionally invalid and quashed.
