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The article explains that a scrutiny assessment becomes invalid when the mandatory notice under Section 143(2) is issued by an officer lacking lawful pecuniary jurisdiction. It highlights that such jurisdictional defects cannot be cured through later transfer of the case.
The reassessment is challenged as being founded solely on an unauthenticated photocopy with no corroboration. Such material fails the “reason to believe” test and vitiates jurisdiction.
AY 2015-16 assessment under Section 153C held time-barred. Judicial rulings confirm six-year limit runs from handing over of seized documents to AO.
Learn why a consolidated satisfaction note for multiple assessment years is legally invalid under Section 153C of the Income Tax Act, based on recent court rulings.
Appeal against penalty under Section 271(1)(b) citing ill health, lack of awareness of Faceless Scheme, and procedural lapses. Request for deletion based on valid grounds.
Written submission against wrong cash deposit notice under Section 148A(b), highlighting errors and lack of independent inquiry.
Grounds of Appeal related to the penalty imposed u/s 271(1)(c) of the Act , 1961 AY 2015-16 1. In the facts and circumstances of the case the Ld. Jurisdictional AO is not justified in imposing penalty of 6,54,050.00 on the assessee which is illegal and imposed in a most arbitrary manner and assessee denies her […]
Explore sample grounds of appeal for condonation of delay before ITAT after rejection by CIT(A), NFAC, New Delhi. Legal analysis of errors and sufficient causes presented by the assessee.
Learn how to draft a letter objecting to a notice under Section 148 of the Income Tax Act, 1961. Understand the legal aspects, necessary documentation, and key considerations.
Learn why mere cash deposits arent enough for reopening assessments. Analysis of tangible material requirement and legal implications for accurate income evaluation.
