Category: Income-Tax Act

Archive for the ‘Income-Tax Act’ Category


Rupesh Katilala Savla v. ACIT (2025) 210 ITD 591 (Mum.) (Trib.)

S. 153B : Assessment-Search-Time limit-Assessment of any other person-Satisfaction note was drawn in assessment year 2018-19-Order passed beyond period of limitation of six years-Barred by limitation [S. 143(3),153C]

Chintankumar Rameshbhai Patel v. Dy. CIT (2025) 210 ITD 290 (Rajkot) (Trib.)

S. 153B: Assessment-Search-Time limit-Limitation to pass the assessment order expired on 31.12.2020 [S. 69B, 132,153A, 153C]

Pradeep Singh v. ACIT (2025) 233 TTJ 590 (Delhi) (Trib.)

S. 153C : Assessment-Income of any other person-Search-Satisfaction note prepared without application of mind and without referring to the incriminating material found during the course of Search-Assessment order is quashed..[S. 132]

Dy.CIT v. Aba Builders Ltd. (2025) 233 TTJ 328 (Delhi) (Trib)

S. 153A: Assessment-Search-Addition can not be be made in the absence of incriminating material found during the search. [S. 69A, 69C, 132]

Kalyan Development Corporation v. ACIT (2025) 233 TTJ 413 (Mum) (Trib)

S. 153A: Assessment-Search-No addition can be made merely on the basis of statement-On money-Presumption-Addition is deleted.[S. 132, 153C, 292C]

Neelu Sanjay Gupta (Smt.) Legal Heir of Late Sanjay Gupta v. Dy.CIT (2025) 233 TTJ 29 (Ahd) (Trib)

S. 153A: Assessment-Search-Revenue followed detailed guidelines during the search-Approval under the section cannot be considered as granted mechanically-Matter is restored to CIT(A). [S. 153D]

Arvind Velji Gada v. ITO (Mum) (Trib)(UR)

S. 151 : Reassessment-Sanction for issue of notice–Notice u/s 148 issued beyond 3-year period-As per amended Section 151 (post 01.04.2021), approval from PCCIT/CCIT was required, but approval was taken from PCIT-Reassessment proceedings quashed. [S. 147, 148]

Mohd. Shafiq Cement Store v. ITO [2025] 210 ITD 1 (Amritsar)(Trib.)

S. 151 : Reassessment-Sanction for issue of notice-Approval is granted in mechanical manner-Reassessment is quashed Communication of assessment order-Assessment orders and demand notices issued u/s. 156, without a Document Identification Number (DIN) are unsustainable in law and can be considered invalid. [S. 119, 147 148, 156]

Madras Race Club v. Dy.CIT (2025) 233 TTJ 383 (Chennai) (Trib)

S. 147 : Reassessment-CIT(A) partly allowed the claim against losses-reopening of assessment on same issue-CIT(A) allowed the reopening-Held, reopening not valid as no fresh material on record. [S. 148]

Kailashnath Arunkumar Dube v. ITO (2025) 233 TTJ 720 (Surat) (Trib)

S. 147 : Reassessment-Best judgment assessment-Unexplained money-Entire cash deposit cannot be treated as income-Income of the assessee is estimated at 10 per cent of cash credit and other credit. [S.69A 148, 249(3)]