ITAT held that assessment framed u/s 153C for AY 2011-12 is ...

ITAT quashes IT assessments u/s 153C for 5 years due to invalid 'satisfaction note'.

January 15, 2025

Case Laws Income Tax AT

ITAT held that assessment framed u/s 153C for AY 2011-12 is barred by limitation and vitiated due to lack of valid 'satisfaction note', rendering entire proceedings under s. 153C a non-starter. For AYs 2012-13 to 2015-16, ITAT found legal infirmities in 'satisfaction note' lacking objectivity, vitiating assumption of jurisdiction u/s 153C. Resultant assessment orders passed u/s 153C for these AYs were quashed being non-est.

View Source

← Previous Next →

ITAT held that assessment framed u/s 153C for AY 2011-12 is ...

ITAT quashes IT assessments u/s 153C for 5 years due to invalid 'satisfaction note'.

January 15, 2025

Case Laws Income Tax AT

You may also like:

The ITAT held that the assessment years 2009-10, 2010-11 and 2011-12 were beyond the 10-year limitation period u/s 153C read with Explanation-1 to section 153A. Hence,...

A consolidated satisfaction note was prepared for multiple assessment years instead of separate notes, rendering the assessment proceedings u/s 153C invalid. The ITAT...

The Appellate Tribunal held that the assessment orders issued u/s 153C for the assessment years 2011-12 and 2012-13 were beyond the jurisdiction of the Assessing Officer...

The ITAT held that the period of limitation for issuing a notice u/s 153C is six years from the end of the financial year preceding the date of recording satisfaction....

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...

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...

ITAT invalidated assessments under s.153C read with s.153A for AYs 2011-12 and 2012-13. The AO recorded satisfaction note on 25.09.2018, making AY 2019-20 the relevant...

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

The Income Tax Appellate Tribunal examined the validity of assessments made u/s 153C, considering the gap between the satisfaction note recorded by the Assessing Officer...

Validity of Assessment u/s 153C - The period of six years would have to be reckoned with respect to the date of recording of satisfaction note, not the date of search....

ITAT quashed assessment order made under section 143(3) for AY 2021-22, declaring it void ab initio. The assessment, based on materials from search operations conducted...

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...

The ITAT quashed the assessment order passed under section 143(3) dated 27/03/2015. The Tribunal held that since the satisfaction note for initiating proceedings under...

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...

ITAT determined that for proceedings under section 153C, the relevant assessment years should be AY 2017-18 to 2022-23, based on the satisfaction note recorded by AO on...

Quick Updates: