Tax Management India. Com
Law and Practice  :  Digital eBook
Research is most exciting & rewarding
  TMI - Tax Management India. Com
Follow us:
  Facebook   Twitter   Linkedin   Telegram
Income Tax - Highlights / Catch Notes

Home Highlights March 2024 Year 2024 This

Assessment u/s 153C - inordinate delay in commencement of ...

Case Laws     Income Tax

March 26, 2024

Assessment u/s 153C - inordinate delay in commencement of proceedings - The High court rejected the argument that the proceedings for AYs 2014-15 to 2016-17 were barred by limitation. It clarified that Section 153C, read with Section 153A, allows for assessment or reassessment for six years preceding the search year and for relevant assessment years beyond that, thus encompassing the years in question. - The court found that a consolidated Satisfaction Note suffices the requirements of Section 153C, provided it contains particulars of the incriminating material relevant to the block of AYs. It was determined that the respondents had collated substantial evidence warranting further scrutiny under the Act.

View Source

 


 

You may also like:

  1. 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...

  2. Reopening of assessment v/s assessment u/s 153C - The Appellate Tribunal acknowledged the argument presented by the appellant and emphasized the importance of applying...

  3. Initiation of proceedings as barred by limitation - proviso to section 153C - satisfaction to initiate proceedings u/s 153C was arrived on 15.09.2014 and the six...

  4. Validity of assessment u/s 153C - Period of limitation - Assessment of income of any other person in search proceedings - The proviso in Section 153C(1) includes not...

  5. Revision u/s 263 - Assessment u/s 153C - revision of invalid assessment - the present proceedings being collateral proceedings and if the assessment order is inherently...

  6. 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...

  7. Validity of assessment u/s 153A r.w.r.153C - proceedings under Section 148 of the Act admittedly lapsed - the lack of jurisdiction was not established by the petitioners...

  8. Reopening of assessment u/s 147 or 153C - assessment proceedings were initiated mainly on the information found during the search proceedings - jurisdiction lies to...

  9. Reopening of assessment u/s 147 v/s assessment u/s 153C - proceedings initiated u/s 132 - The correct course of reassessment is under section 153C not under section 147...

  10. Delayed adjudication of show cause notice without reasonable cause - Delay in finalizing assessments and issuing demand - Classification of goods under appropriate...

  11. Recovery of refund granted erroneously - It is settled legal position that inordinate delay in adjudication results into denial of principles of natural justice. In the...

  12. Reopening of assessment u/s 147 - no original assessment order in the case of the assessee passed - Even assuming for the sake of argument that if an intimation under...

  13. The HC quashed the show cause notice pending adjudication for over 15 years due to inordinate and unexplained delay by the respondent. The respondent's affidavit failed...

  14. Assessment u/s 153C - Profit estimation on money received for new construction and redevelopment projects - extrapolation of income for the search period. The assessee...

  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...

 

Quick Updates:Latest Updates