Income Tax : A guide to India's block assessment tax provisions from the Finance Act 2024. Understand pending assessments, undisclosed income, ...
Income Tax : The Tribunal ruled that the Revenue must establish a direct connection between seized material and the assessee’s taxable income...
Income Tax : The Court held that recording satisfaction after a delay of nine months was not immediate as required by law. It upheld quashing o...
Income Tax : The issue was whether third-party diaries and loose papers could establish receipt of unaccounted income. The Tribunal ruled that ...
Income Tax : The High Court held that issuing a draft assessment order under Section 144C is invalid where the Transfer Pricing Officer propose...
Income Tax : Since the statutory notice under section 143(2) was issued by a non-jurisdictional officer, the assessment collapsed. The ruling a...
That once the AO became aware that the property was not owned by the assessee and that he had received the amount on someone else’s behalf, notice could not have been issued under Section 158BD. He urged that this Court should not interfere with the ITAT’s order on this ground alone.
Hon’ble High Court is of the opinion that the note written by the AO lacks satisfaction as required u/s 158BD.In other words there is lack of the satisfaction of the AO that there is material that the respondent assessee had undisclosed income.
Revenue has to be vigilant in issuing notice to the third party under Section 158 BD, immediately after the completion of assessment of the searched person, this Court is of the opinion that a delay ranging between 10 months of 1 ½ years cannot be considered contemporaneous to assessment proceedings.
