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Income Tax : Understand how interest under the Income Tax Act is calculated, including Sections 234A–234D, 244A, and Rule 119A mechanics for ...
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Income Tax : Whistleblower reward of Rs. 8.16 crore received by the assessee from the U.S. SEC for providing information and substantial assist...
Income Tax : Mumbai ITAT held that a reassessment notice issued beyond three years was invalid because approval was obtained from the Principal...
Income Tax : ITAT Mumbai held that reassessment proceedings were invalid because approval under Section 151 was obtained from an authority not ...
Income Tax : The ITAT Mumbai held that a reassessment notice issued beyond three years was invalid where the alleged escaped income was less th...
Income Tax : Adjustment under section 143(1)(a)(iv) based on disallowance reported in Form 3CD was held to be within CPC's jurisdiction. Howeve...
Whistleblower reward of Rs. 8.16 crore received by the assessee from the U.S. SEC for providing information and substantial assistance in enforcement proceedings was a taxable revenue receipt.
Mumbai ITAT held that a reassessment notice issued beyond three years was invalid because approval was obtained from the Principal CIT instead of the prescribed higher authority under Section 151. The reassessment proceedings and assessment order were quashed.
ITAT Mumbai held that reassessment proceedings were invalid because approval under Section 151 was obtained from an authority not competent under the amended law. The notice under Section 148 was declared void.
The ITAT Mumbai held that a reassessment notice issued beyond three years was invalid where the alleged escaped income was less than ₹50 lakh. The consequential assessment order was quashed.
Adjustment under section 143(1)(a)(iv) based on disallowance reported in Form 3CD was held to be within CPC’s jurisdiction. However, rectification under section 154 enhancing income without complying with section 154(3) was quashed.
Mumbai ITAT ruled that where a capital asset was acquired before 01.04.2001, the claim for adopting fair market value as on that date must be examined on merits. The key takeaway is that statutory valuation rights cannot be rejected on technical grounds alone.
The Mumbai ITAT held that reassessment initiated beyond three years was invalid because the alleged escaped income was only ₹5 lakh, far below the ₹50 lakh requirement under Section 149(1)(b). As a result, the reassessment and consequential assessment order were quashed.
The Tribunal sent the issue of deduction for political donations back to the Assessing Officer after finding that bank transaction details had not been properly verified. Fresh adjudication was directed after giving the assessee an opportunity of hearing.
Assessments arising from searches conducted after 01.04.2021 must strictly comply with the reassessment framework under sections 147 and 148. Failure to adhere to statutory jurisdictional requirements, including mandatory approvals and satisfaction for use of third-party material, rendered the entire assessment void.
The ITAT held that once an assessment order under Section 143(3) was passed, the earlier intimation under Section 143(1) merged into it. As a result, the appeal against the intimation became infructuous.
