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 Supreme Court confirmed that reassessment powers under Section 148 cannot be used to bypass the statutory scheme for search cases. The decision clarifies the distinct operating fields of Sections 153C and 148.
The Court held that reassessment based solely on material seized in a third-party search must proceed under Section 153C, not Section 148. Notices issued under the general reassessment provision were set aside.
The Tribunal restored the matter after finding that the appellate authority failed to decide the assessees grounds on merits. The case was remanded for fresh adjudication with directions to consider all documents.
The issue was whether purchases recorded by the assessee were genuine. The Tribunal held that seized Tally data and statements proved bogus purchases, justifying full addition.
ITAT Delhi held that satisfaction note recorded before initiation of the proceedings u/s 153C of the Income Tax Act is not a valid satisfaction. Accordingly, proceedings u/s. 153C of the Income Tax Act is quashed since based on invalid satisfaction.
The Tribunal held that reopening AY 2012–13 after a post-2021 search was barred by limitation. Applying Supreme Court guidance, it ruled that older limitation periods protect concluded assessments from retrospective reopening.
Additions under Sections 68 and 69C were set aside after the Tribunal found the mandatory approval to be a mere formality. The ruling reinforces that Section 153D approval is not a procedural ritual.
The tribunal ruled that reassessment beyond four years is barred when reasons do not allege failure to disclose material facts. Mere suspicion of escaped income is insufficient to override the statutory limitation.
The Revenue argued that incriminating material justified Section 153C action against a non-searched person. ITAT held that High Court quashing of notices conclusively ends jurisdiction under Section 153C.
The Tribunal set aside the appellate order after finding that the appeal was not adjudicated on merits. The matter was remanded to ensure proper consideration after granting adequate opportunity of hearing.
