Income Tax : The Income Tax Act, 2025 replaces old reassessment provisions with Sections 279 to 286 and increases reopening timelines in certai...
Income Tax : Explains how routine approvals under Section 151 can nullify reassessment proceedings. The key takeaway is that lack of applicatio...
Income Tax : The ITAT held that reassessment cannot run parallel to ongoing scrutiny proceedings. Such action was declared without jurisdiction...
Income Tax : The High Court held that reassessment proceedings for AY 2013-14 were time-barred after computing the surviving limitation as clar...
Income Tax : A detailed look at how the Finance Act, 2021 reshaped Sections 147–151, introduced Section 148A, and reduced limitation periods ...
Income Tax : Discover how Finance Act 2021 revamped assessment and reassessment procedures under Income-tax Act, impacting notices, time limits...
Income Tax : Humble Representation for modification of Section 151 of the Income Tax Act relating to Sanction for issue of Notice under sec. 14...
Income Tax : Income Tax Gazetted Officers’ Association requested CBDT to issue Clarification in respect of the judgement of Hon’ble Supreme...
Income Tax : In view of Indiscriminate notices by income Tax Department without allowing reasonable time it is requested to Finance Ministry an...
Income Tax : Lucknow CA Tax Practicioners Association has made a Representation to FM for Extension of Time Limit for Assessment cases time bar...
Income Tax : ITAT Delhi held reassessment orders invalid because the assessee was not supplied with the recorded reasons for reopening under Se...
Income Tax : The Supreme Court dismissed the challenge to a Delhi High Court ruling that quashed reassessment proceedings under Sections 148A(d...
Income Tax : The Telangana High Court held that reassessment proceedings initiated by the Jurisdictional Assessing Officer after implementation...
Income Tax : Gujarat HC held that reassessment under Sections 147 and 148 was valid where Assessing Officer received fresh investigation materi...
Income Tax : The Delhi High Court held that reassessment proceedings under Section 148 were invalid where the Assessing Officer sought to make ...
Income Tax : The department has identified high-risk cases through its Insight Portal for AYs 2022-25. It directs officers to initiate reassess...
Income Tax : Supreme Court in the matter of Shri Ashish Agarwal, several representations were received asking for time-barring date of such cas...
Corporate Law : Income Tax Gazetted Officers’ Association (W.B.) Unit Date: 02.02.2023. To The Principal Chief Commissioner of Income Tax, W...
Income Tax : CBDT directed that cases reopened u/s 147/148A in consonance with Judgement of SC in case of UoI vs. Ashish Agarwal & CBDT instruc...
Income Tax : Consequent to order passed by Allahabad High Court passing severe strictures and proposing to levy exemplary cost of Rs 50 lakhs i...
ITAT Delhi held reassessment orders invalid because the assessee was not supplied with the recorded reasons for reopening under Section 148. The Tribunal ruled that such non-compliance violated the law laid down in GKN Driveshafts.
The Supreme Court dismissed the challenge to a Delhi High Court ruling that quashed reassessment proceedings under Sections 148A(d) and 148. The courts held that reassessment cannot be sustained on allegations that change after issuance of the original notice.
The Telangana High Court held that reassessment proceedings initiated by the Jurisdictional Assessing Officer after implementation of the Faceless Assessment Scheme were without jurisdiction. It quashed notices issued under Sections 148A and 148 along with consequential orders.
Gujarat HC held that reassessment under Sections 147 and 148 was valid where Assessing Officer received fresh investigation material alleging accommodation entries. Court observed that prima facie tangible material is sufficient at reopening stage.
The Delhi High Court held that reassessment proceedings under Section 148 were invalid where the Assessing Officer sought to make the same additions already annulled by the CIT(A). The Court upheld the Tribunal’s decision quashing the reassessment order.
SC dismissed Revenue’s challenge against Calcutta HC ruling that reassessment proceedings based only on suspicion and investigation reports were invalid under Section 147.
The Calcutta High Court held that reassessment proceedings cannot be reopened merely on suspicion arising from investigation reports. The Court ruled that “reason to believe” must be based on independent application of mind and material evidence.
The Income Tax Act, 2025 replaces old reassessment provisions with Sections 279 to 286 and increases reopening timelines in certain cases. Tax professionals must carefully examine applicability based on the relevant tax year.
The Supreme Court upheld the High Court ruling that approval stating fit case for reopening satisfied Section 151 requirements. The reassessment proceedings linked to alleged accommodation entries were restored.
The Supreme Court refused to interfere with the Gujarat High Court ruling quashing reassessment proceedings where the assessee had disclosed all transactions in audited accounts and income tax returns. The Court left the question of law open.
