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...
Legal forums at various levels have been annulling assessment orders framed u/s 153C(1) in case of ‘other person’ (the non-searched person) for some of the assessment years out of a totalpermissible period of six assessment years on the ground that they fall beyond the relevant period if reckoned from the year of recording satisfaction/handing over of seized material, as opposed to the statutory provisions, which require the reckoning of the aforesaid period from the year of initiation of search itself,in the same manner as provided u/s 153A.
Section 153C as part of provisions of search assessment lays down the law relating to the assessment of persons other than the searched person. The author in this article discusses the situation arising from interpretation of provisions relating to the years to be considered u/s 153C assessment in the light of judicial pronouncements and the amendment brought in by the Finance Act 2017.
In the present case, the A.O, came to the conclusion that since assessee company purchased the same shares just after 05 days from TIDCL at a much lower price, therefore, assessee must have paid the sale consideration outside the books of account. Accordingly, A.O. in the assessment order held that assessee has paid to TIDCL outside books of account and made addition accordingly.
Unraveling complexities in Income Tax Search & Seizure Operations: AO scenarios, New Claims, Section 143(2) Notice, Section 132 compliance, and the scope of Section 153A. Explore recent judgments and expert analysis.
Legality of Prior approval of Joint Commissioner of Income Tax for assessment in search cases under Section 153D of Income Tax Act, 1961
DCIT Vs Late Shri Pravinsinh N Zala (ITAT Rajkot) Whether the amendment brought under the provisions of section 153C of the Act, where the word ‘belong’ was replaced with the word ‘pertain’ is applicable for the year under consideration. It was only on 1st June, 2015 when the amended provisions came into force that the […]
ITAT Remit Back the case of Actor Dulquer Salmann (Assessee) back to Assessing Officer (AO) as Information reconciling source for investments which were added as undisclosed income were placed before it but not placed before AO.
The assessee challenged the jurisdiction as the Assessing Officer has not given any separate satisfaction for the assessee and only a mechanical satisfaction was recorded.
Understanding the law of recording satisfaction when AO of searched person and other person is the same. Analysis of a recent Supreme Court judgment.
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?
