Home Highlights March 2014 Year 2014 This

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1. 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...

2. Block Assessment - satisfaction note is sine qua non and must be prepared by the AO before he transmits the records to the other AO who has jurisdiction over such other person - SC

3. 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...

4. Undisclosed Capital gain - Scope of block assessment proceedings - AO is concerned only with undisclosed income and he has no power to consider material and evidence not...

5. 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...

6. 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...

7. 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...

8. Reopening of assessment u/s 147 - The entire exercise of re-opening would depend upon the reasons recorded by the AO and therefore the reasons recorded to re-open the...

9. 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...

10. Assessment u/s 153C/153A - Computation of the Relevant Assessment Years Block - Jurisdiction for Reopening Assessments - The Delhi High Court meticulously analyzed the...

11. Reopening of assessment u/s 147 - Pr.CIT has recorded his satisfaction for reopening of the assessment in a most mechanical manner without considering even the...

12. Validity of assessment u/s 158BC r.w.s. 158D - The satisfaction recorded by the AO as per Revenue is incorporated in the order sheet and not in the notice. Thus, it is...

13. 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...

14. Disallowance u/s 14A - necessity of recording satisfaction - Dissatisfaction of the AO is expressly recorded in the assessment order. The said dissatisfaction has been...

15. Notice u/s 148 - AO has not recorded any reasons for re-assessment proceedings and merely acted on the borrowed satisfaction recorded by another AO without jurisdiction...