Section 153C Proceedings Invalid if Satisfaction Note Recorded After 01.04.2021: Important Tribunal Ruling In a significant ruling impacting search-related assessments involving third parties, the Tribunal has held that proceedings under Section 153C of the Income Tax Act are not maintainable where the satisfaction note was recorded after 01.04.2021. The Tribunal, in Shaminder Singh vs. ACIT, quashed…

Opening Balance of Unsecured Loans Cannot Be Taxed Under Section 68: Important ITAT Delhi Ruling     In a significant relief for taxpayers facing additions relating to unsecured loans, the Delhi Bench of the Income Tax Appellate Tribunal (ITAT Delhi) has reiterated an important legal principle that Section 68 of the Income Tax Act applies…

“Beneficial Provision Cannot Be Eclipsed by Procedural Formalism”: ITAT Chandigarh Grants Full Section 54 Relief Despite Joint Ownership In a significant ruling on interpretation of capital gains exemption provisions, the Chandigarh Bench of the Income Tax Appellate Tribunal (ITAT Chandigarh) has strongly criticized the Revenue’s hyper-technical approach and reaffirmed that beneficial provisions under the Income…

Undated “Reasons to Believe” and Mechanical Approval Under Section 151 Render Reassessment Invalid: Delhi ITAT Quashes Assessment   In a significant ruling strengthening taxpayer safeguard in reassessment proceedings, the Delhi Bench of the Income Tax Appellate Tribunal (ITAT Delhi) has quashed reassessment proceedings on the ground that: •  The “reasons to believe” recorded under Section…

Delay of Just 13 Days in Filing Form 10-IC Could Have Cost ₹5 Crore – Bombay High Court Restores Section 115BAA Benefit     In a major relief for corporate taxpayers opting for the concessional tax regime under Section 115BAA, the Bombay High Court has delivered an important judgment emphasizing that procedural delays cannot defeat…