Income Tax : The FAQs explain the revised CBDT guidelines on compounding offences under the Income-tax Act effective from 17 October 2024. They...
Income Tax : The article explains who can file appeals before the Income Tax Appellate Tribunal, the orders that are appealable, applicable tim...
Income Tax : The Tribunal held that additions cannot stand without a clear link between seized material and the assessee. It ruled that third-p...
Income Tax : Judicial rulings clarify that satisfaction for initiating action against other persons in search cases must be recorded promptly. ...
Income Tax : CBDT's new Compounding of Offence Guidelines (2024) simplify the process but maintain strict compliance rules. Learn about eligibi...
Income Tax : Learn about the new block assessment provisions for cases involving searches under section 132 and requisitions under section 132A...
Income Tax : Gujarat High Court held that rejection of a Vivad se Vishwas declaration was invalid because final assessment arose from survey pr...
Income Tax : The Tribunal held that an addition under Section 69 could not be sustained solely on the basis of a seized loose sheet without ind...
Income Tax : The ITAT held that assessments under Section 153A were invalid because no search warrant was issued in the assessee’s name. As t...
Income Tax : The ITAT Hyderabad held that the assessment orders were time-barred under Section 153 despite the DRP process. Both assessments we...
Income Tax : The ITAT held that limitation under Section 153B had to be computed from the searched person's last panchanama, making the assessm...
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...
Karti P. Chidambaram Vs Principal Director of Income Tax (Investigation) (Madras High Court) All these writ petitions are filed, challenging the Show Cause Notices issued under Section 153C of the Act. The procedures for assessment / reassessment are yet to commence. The petitioners are expected to avail the opportunity and defend their case in the […]
Raju Bhupendra Desai Vs ITO (Gujarat High Court) There is also no merit in the submission of Mr. Patel that the respondent was carrying out fishing and roving inquiry completely on incorrect facts and based on the borrowed belief of DCIT Central Circle-1(3), Ahmedabad. It may be noted that merely because in the reasons recorded […]
Author: Anadi Varma NEW REASSESSMENT PROCEDURE 1. Introduction: In the film JOLLY LLB, the judge, unforgettably played by actor Saurabh Shukla, in the concluding speech while delivering his judgment says: ‘But I am the judge. who knows what, what I feel, judgment cannot be given on that basis. I HAVE TO GIVE JUDGMENT ON THE […]
Onus was on Revenue to show that the incriminating material/documents recovered at the time of search ‘belongs’ to the Assessee, in other words, it was not enough for the Revenue to show that the documents either ‘pertain’ to the Assessee or contains information that ‘relates to the Assessee.
ACIT Vs. K. S. Chawla & Sons (HUF) (ITAT Delhi) > HELD THAT:- In the present assessee’s case, search & seizure action u/s 132 of the Act was carried out on 15.10.2009 in the premises of Mr. Abhinav Arora and Mrs. Ranju Arora. Consequently, the Assessing Officer initiated reassessment proceedings u/s 147 of the Act […]
Central Government has decided to extend the time limits to 30th June, 2021 in the following cases where the time limit was earlier extended to 30th, April 2021 through various notifications issued under the Taxation and Other Laws (Relaxation) and Amendment of Certain Provisions Act, 2020, namely:-
In search assessment, any undisclosed income, which can ultimately be added, is only to the extent of any unrecorded assets/material found or any incriminating documents found as representing undisclosed income earned, since, AO had not made any specific reference to the incriminating material found during the search in respect of additions made by him, therefore, assessment so framed, was bad in law.
S. R. Trust Vs ACIT (Madras High Court) Conclusion: Search proceedings had been rightly initiated as assessee had nothing to fear, they could as well place all the materials before AO for consideration and more so, the jurisdictional facts exist for assumption of jurisdiction under Section 153A as well as Section 153C of the Act. […]
ACIT Vs Himalaya Darshan Developers (Gujarat) Pvt. Ltd. (ITAT Ahmedabad) The question that arises for our adjudication whether the document in the form of tally and balance sheet found during the course of search is an incriminating document in nature. In our considered view such document are not an incriminating material, as such those documents […]
No satisfaction note have been recorded under section 153C of the I.T. Act. The A.O. passed the assessment order for the assessment year under appeal i.e., 2013-2014 under section 143(3) considering the preceding A.Y. 2012-2013 to the year of the search.
