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Section 153C

Latest Articles


Loose Sheets and Digital Data Not Enough: ITAT Quashes Additions for Lack of Evidence

Income Tax : The Tribunal held that additions cannot stand without a clear link between seized material and the assessee. It ruled that third-p...

May 1, 2026 339 Views 0 comment Print

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 1866 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 2064 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 3219 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 3036 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 2277 Views 0 comment Print


Latest Judiciary


Reassessment Quashed as AO Used Section 147 Instead of Mandatory Section 153C

Income Tax : ITAT Ahmedabad held that reassessment based solely on search material seized from a third party must be initiated under Section 15...

May 20, 2026 264 Views 0 comment Print

Mere Search Allegations Against Lender Cannot Make Every Loan Bogus: ITAT Mumbai

Income Tax : Mumbai ITAT held that unsecured loans received through banking channels and fully recorded in books cannot be treated as unexplain...

May 19, 2026 180 Views 0 comment Print

Section 68 Addition Deleted – ITAT Says Investigation Wing Report Alone Cannot Prove Bogus Share Capital

Income Tax : Delhi ITAT held that additions under Section 68 cannot be sustained merely on Investigation Wing reports without independent enqui...

May 19, 2026 177 Views 0 comment Print

Consolidated Satisfaction Note for Multiple Years Held Invalid – ITAT Quashes Entire U/s 153C Assessments

Income Tax : Delhi ITAT held that a single consolidated satisfaction note covering multiple assessment years without identifying year-wise incr...

May 19, 2026 135 Views 0 comment Print

Assessment Quashed for Wrong Section – ITAT Holds AY Falling Within U/s 153C Block Cannot Be Assessed U/s 143(3)

Income Tax : The Tribunal ruled that the Assessing Officer wrongly invoked Section 143(3) despite the case being covered under the block assess...

May 19, 2026 75 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 71370 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 2493 Views 0 comment Print


Proceedings u/s 153C not valid in absence of any relevant seized material

December 7, 2015 1001 Views 0 comment Print

Delhi High Court held In the case of CIT vs. M/s Refam Management Services (P) Ltd. that under Section 153C the assessment or reassessment of income of a person other than a searched person would proceed in accordance with the provisions of Section 153A.

Notice u/s 153C invalid if no satisfaction been recorded by Assessing Officer

November 17, 2015 851 Views 0 comment Print

ITAT-Ahmedabad In the case of M/s Shiv Associates v DCIT quashed the notice u/s 153C relying on the Judgment of the similar case related to the assessee in which the notices u/s 153C were quashed as no satisfaction was recorded by the AO.

Search Warrant against Members of HUF cannot be deemed to be also against HUF

November 14, 2015 993 Views 2 comments Print

Shri Govind G. Sarawagi HUF Vs. ACIT (ITAT Ahmedabad)- Name of the HUF, who is separate taxable entity, is no where available in the Panchnama. It is also pertinent to note that all the members of the HUF were not covered under the search action.

Principles & Procedures of Assessment u/s 153C

November 1, 2015 11919 Views 0 comment Print

a person other than the person referred to in section 153A, then, the books of account or documents or assets, seized or requisitioned shall be handed over to the Assessing Officer having jurisdiction over such other person ] and that Assessing Officer shall proceed against

Finding of photocopies with searched person does not mean they belong to person holding originals

November 1, 2015 2188 Views 0 comment Print

Pepsico India Holdings Private Ltd vs. ACIT (Delhi High Court)-Possession of documents and possession of photocopies of documents are two separate things. While the Jai puria Group may be the owner of the photocopies of the documents it is quite possible that the originals may be owned by some other person.

Search at house of partner cannot be deemed as search on assessee firm

October 30, 2015 1896 Views 0 comment Print

ACIT Vs. S.P.Cold Storage (ITAT Raipur)- Mere mentioning of name in Search Warrant & Panchanama not sufficient for contemplating search against the assessee firm, Search at the residential premises of the Partners could not be deemed to be a search on the assessee firm

Whether Section 153C enables AO to issue notice to third parties on the basis of entries in some documents

September 15, 2015 1442 Views 0 comment Print

A search took place on 14.02.2006 in the premises of M/s Radico Khaitan.In the course of these search proceedings, various documents including reports narrating amounts alleged to have been received or receivable from various members of the UPDA and the basis thereof were recovered.

Recording of satisfaction mandatory prior to issuing notice u/s 153C & it should not be vague

September 11, 2015 1247 Views 0 comment Print

ITAT Ahmedabad in the case of M/s. Parshwa Corporation Vs. DCIT observed the basic necessities & condition for issuing notice u/s 153 C and it was held that it is mandatory to follow the procedure prescribed under the section i.e. (1) Satisfaction is to be recorded by the Assessing Officer of the persons searched;

Scope of additions that can be made in a pending assessment and in a completed assessment pursuant to a search u/s 132

September 2, 2015 2920 Views 0 comment Print

Completed assessments can be interfered with by the AO while making the assessment under Section 153 A only on the basis of some incriminating material unearthed during the course of search or requisition of documents or undisclosed income or property discovered in the course

Search Assessment can be made only on the basis of incriminating material found during search

August 11, 2015 1352 Views 0 comment Print

In an appeal no.523/2013, the assessee was engaged in the operation of a Container Freight Station (CFS). It filed a return of income on 08.10.2008 declaring total income at Rs. Nil after claiming deduction of Rs.210713675/- u/s 80IA(4) of the Income Tax Act,1961

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