Income Tax : Examine the legal disputes surrounding Section 153D approvals for tax assessments, including court rulings on mechanical approvals...
Income Tax : The Tribunal held that approval granted under Section 153D without application of mind was invalid. As a result, search assessment...
Income Tax : ITAT Delhi upheld CIT(A) s order holding that reassessment under Section 153A cannot stand without incriminating material seized f...
Income Tax : ITAT Delhi held that recording a single satisfaction note for multiple assessment years violates Section 153C requirements. As no ...
Income Tax : The Tribunal set aside the assessment after finding that a combined approval under Section 153D for multiple years vitiated procee...
Income Tax : ITAT held that the Assessing Officer failed to record proper satisfaction linking seized material to the assessee’s income. Cons...
The Tribunal held that approval granted under Section 153D without application of mind was invalid. As a result, search assessments framed under Section 153C for multiple years were quashed.
ITAT Delhi upheld CIT(A) s order holding that reassessment under Section 153A cannot stand without incriminating material seized from the assessee. The Revenue’s appeal was dismissed.
ITAT Delhi held that recording a single satisfaction note for multiple assessment years violates Section 153C requirements. As no year-specific incriminating material was identified, the assessments were quashed along with the related penalty.
The Tribunal set aside the assessment after finding that a combined approval under Section 153D for multiple years vitiated proceedings. It held that such approval renders the assessment legally unsustainable.
ITAT held that the Assessing Officer failed to record proper satisfaction linking seized material to the assessee’s income. Consequently, proceedings under Section 153C were quashed.
ITAT ruled that a 76/23 split in chats reflected proposed refurbishment costs, not undisclosed cash consideration. In absence of corroborative material, addition under Sections 69 and 115BBE was held unsustainable.
ITAT held that a portion of cash paid could reasonably be sourced from accumulated withdrawals from joint bank accounts. The remaining unexplained amount was reduced on an estimated basis.
The Tribunal held that assumption of jurisdiction under Section 153C was invalid due to a defective and consolidated satisfaction note. As the mandatory requirement of year-wise satisfaction was not met, the entire assessment was quashed.
The Tribunal noted that the subject line of the approval letter excluded the concerned assessment year, evidencing lack of scrutiny. It held that such defective approval invalidates the assessment.
The approving authority issued one common approval for multiple years without demonstrating examination of records. The Tribunal ruled such ritualistic approval vitiates the entire assessment.
