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The Conversion Doctrine: Legal Validity of Converting a Section 133A Survey into a Section 132 Search under the Income Tax Act
Introduction The Indian tax administration system operates through distinct investigative mechanisms designed to detect and prevent tax evasion. Among these, the Income Tax Act, 19
Surveys under Section 133A: The Third-Party Trap in Chartered Accountant Offices
Introduction The Income Tax Department wields significant investigative powers to detect tax evasion and ensure compliance with fiscal laws. Among these powers, the authority to co
CBDT Office Memorandum 2025: Risk Management Strategy (RMS) Exemption for Search and Survey Cases – Streamlining Reassessment or Legal Loophole?
Introduction The Central Board of Direct Taxes (CBDT) issued an Office Memorandum on February 27, 2025, fundamentally altering how search and survey case information flows through
Section 133A of the Income Tax Act Post Finance Act 2022: Survey Approval Framework & Legal Challenges
Introduction The Finance Act 2022 introduced significant amendments to Section 133A of the Income Tax Act, 1961, fundamentally altering the landscape of survey operations conducted
Evidentiary Treatment of Loose Sheets in Income Tax Survey and Search Operations
Introduction During income tax survey and search operations conducted under the Income Tax Act, 1961, authorities frequently encounter loose sheets containing various notati
