Home Highlights August 2014 Year 2014 This

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

2. Section 153C provisions are inapplicable as notice was issued to 'other person' under this section. Computation of six-year block period preceding assessment year...

3. Validity of Assessment u/s 153C - recording satisfaction note - In the present case there is neither the recording of satisfaction by the AO of the searched person that...

4. Validity of assessment proceedings initiated u/s 153C - In case of other person u/s 153C of the Act, the starting point for computation of the block period would be the...

5. Validity of the assessment order passed u/s 153C read with Section 153A and 143(3) - satisfaction of the AO of the person searched is essential for assuming the...

6. Validity assessment proceedings u/s 153C - recording of satisfaction - The ITAT examined the language of Section 153C and referenced the judgment in Ganpati Fincap...

7. Owner of Cash found and seized in course of search - Undisclosed income - presumption u/s 292C - if money is found in possession of any person in course of search u/s...

8. 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...

9. Assessment u/s 153A or u/s 147/148 - any incriminating information of any undisclosed income of the person not searched which was found during the course of a search...

10. Effect of amendment in Section 153C w.e.f .1st June, 2005 - law applicability on search prior to amendment and notice u/s 153C issued after amendment - amendment brings...

11. Assessment u/s 153A - Addition u/s 69A by the Assessing Officer on account of difference in amount credited in bank and sale proceeds shown in the income tax return. It...

12. Validity of assessment framed u/s 153C - Search conducted at secret office of searched person - Definition of "Books and Books of Accounts" u/s 2(12A) includes...

13. Interpretation of section 153C - power of AO to assess the income of any other person – merely because the document evidencing the transaction was in possession of the...

14. 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...

15. Section 153C applies equally to all non-searched entities, without creating a separate regime where the AO of the searched and non-searched entity are the same. The...