Home Highlights April 2014 Year 2014 This

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1. Assessment u/s 153C - For the purpose of Section 158-BD of the Act, a satisfaction note is a sine qua non and must be prepared by the Assessing Officer before he...

2. Assessment u/s 153A - Need for spelling out ‘Satisfaction note’ - the ld. CIT(A) while adjudicating the legal issue of the validity of the satisfaction note prepared by...

3. Penalty u/s 271D - violation of provisions u/s 269SS - cash receipt claimed as advance against sales - recording of the satisfaction by the AO is sine qua non for...

4. The assessment u/s 153C mandates the recording of satisfaction by the Assessing Officer (AO) upon discovery of material likely to "have a bearing on the determination of...

5. Validity of assessment u/s 153C - There is no prohibition in the Act that a combined satisfaction-note should not be recorded. Moreover, the satisfaction- note, is...

6. Validity of Initiation of proceedings u/s 153C - as argued satisfaction note of the searched person and satisfaction note of the petitioner (other than the searched...

7. Assessment u/s 153C - Unexplained investment being share capital and share premium - no incriminating material seized during search. CIT(A) held that three conditions...

8. Absence of valid satisfaction recorded by AO before initiating assessment under special provision where search took place. Satisfaction note did not reveal AO's averment...

9. Disallowance u/s 14A - it was incumbent for Ld. AO to record a satisfaction as to why the disallowance offered by the assessee was not sufficient and this said...

10. Validity of Assessment u/s 153C - whether AO of the searched person has not recorded satisfaction note that the books of accounts/material belongs to the assessee ? - In...

11. Penalty u/s 271(1)(c) - non recording of satisfaction - When satisfaction for initiation of penalty proceedings u/s 271(1)(c) of IT Act is recorded by the AO in...

12. Assessment framed u/s. 153C/263/143(3) - Such satisfaction note along with seized material is passed over to the ld. AO of ‘other person’. Thereafter, the ld.AO of the...

13. Rectification u/s 254 - ITAT refused to admit additional ground - Having found that the recording of satisfaction by the AO of the searched person is mandatory; which is...

14. Concealment of turnover - validity of assessment and Levy of penalty - recording of satisfaction is sine qua non before proceeding to impose tax and penalty upon the...

15. Assessment u/s 153C versus 143 - Additions u/s 45 - Underreporting of sale consideration for immovable property while framing the Assessment Order u/s 143(3) - Whether...