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...
Reopenings based on assumptions, conjecture, or generalized allegations were struck down. The ruling reiterates that reasons must show tangible material, application of mind, and a live nexus with escaped income.
Revenue failed to produce a Section 153C satisfaction note showing the date of handing over seized material. ITAT treated the notice date as the deemed search date and held AY 2012-13 beyond jurisdiction.
The issue was whether an assessment could survive when statutory notices were issued in the name of a deceased person. The Tribunal held such notices invalid and quashed the entire assessment.
ITAT Delhi held that for an unabated year, additions under section 153A require incriminating material. A seized loose sheet and retracted statements lacked corroboration, leading to deletion of the ₹100 crore addition.
The tribunal ruled that statements of third parties cannot be relied upon unless the assessee is provided copies and allowed cross-examination. Denial of this right renders the additions legally untenable.
ITAT Mumbai deleted ₹20,000 yearly penalties where assessments under section 153C accepted returned income with no additions, holding notice non-compliance as merely technical.
The Tribunal considered whether RTGS credits constituted unexplained money. It ruled that once sale bills, customer ledgers, and bank entries align, Section 69A has no application.
The decision reiterates that once the assessees death is known, proceedings must restart with a valid notice to the legal heir. Failure to do so makes the assessment unsustainable.
It was ruled that the date of recording the satisfaction note is the deemed search date for a non-searched person. The ten-year limitation must be counted from this date, not from the original search.
The Tribunal deleted both substantive and protective additions made across multiple years on the same alleged receipts. It held that such duplication results in impermissible multiple taxation of identical amounts.
