Home Highlights April 2014 Year 2014 This

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1. Assessment u/s 153C - For the purpose of Section 158-BD of the Act, a satisfaction note is a sine qua non and must be prepared by the Assessing Officer before he...

2. Penalty u/s 271D - violation of provisions u/s 269SS - cash receipt claimed as advance against sales - recording of the satisfaction by the AO is sine qua non for...

3. 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...

4. 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...

5. 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...

6. Disallowance u/s 14A - it was incumbent for Ld. AO to record a satisfaction as to why the disallowance offered by the assessee was not sufficient and this said...

7. Validity of Assessment u/s 153C - whether AO of the searched person has not recorded satisfaction note that the books of accounts/material belongs to the assessee ? - In...

8. Penalty u/s 271(1)(c) - non recording of satisfaction - When satisfaction for initiation of penalty proceedings u/s 271(1)(c) of IT Act is recorded by the AO in...

9. Assessment framed u/s. 153C/263/143(3) - Such satisfaction note along with seized material is passed over to the ld. AO of ‘other person’. Thereafter, the ld.AO of the...

10. Rectification u/s 254 - ITAT refused to admit additional ground - Having found that the recording of satisfaction by the AO of the searched person is mandatory; which is...

11. Concealment of turnover - validity of assessment and Levy of penalty - recording of satisfaction is sine qua non before proceeding to impose tax and penalty upon the...

12. 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...

13. Assessment u/s 153C - existence of satisfaction note - The satisfaction note of the AO of the Assessee, being a carbon copy of the satisfaction note of the AO of the...

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

15. Reopening of assessment u/s 147 - Scope of conditions as envisaged as per provisions of Section 151 - in the present case, the conditions U/s 151 of the Act for...