Income Tax : Explore the Bombay High Court's ruling on the invalidity of a reassessment notice under Section 148 of the Income-tax Act, 1961, f...
Income Tax : Learn about Section 147 to 153 Income Escaping Assessment and Reopening of Cases Under Income Tax Act, 1961. Get guidance on the p...
Income Tax : Explore legality of Section 148A(b) & Section 148A(d) proceedings post Finance Act 2021. Understand implications of local assessm...
Income Tax : In a recent case, Madras High Court rules on reassessment proceedings against a struck-off company, highlighting the need for rev...
Income Tax : Understand the critical role of the initial enquiry under Section 148A(a) for taxpayer protection in income tax assessments. Explo...
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 : Under the provisions of Income-tax Act, 1961, notices for assessment/reassessment of income of old cases of more than six years fr...
Income Tax : PCIT Vs Farmson Pharmaceuticals Gujarat Pvt Ltd (Gujarat High Court): Reassessment cannot be solely based on a reevaluation of exi...
Income Tax : Himachal Pradesh High Court quashes reassessment notice for J.B.J. Perfumes Pvt. Ltd. based on 'Change of Opinion'. Learn about th...
Income Tax : Analysis of Swarn Singh Vs ITO (ITAT Amritsar) on validity of notice u/s 148 by Jurisdictional Assessing Officer (JAO) vs Faceless...
Income Tax : Learn why a reassessment notice issued under Section 148 beyond the four-year period from the end of the relevant assessment year ...
Income Tax : Reassessment proceedings initiated by officers without jurisdiction and completed by different officers without recording fresh re...
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...
Income Tax : Salient features of new Section 148 to 151A 'i.e. assessment/reassessment procedure of Income Escaping Assessment...
It is held that while considering the material on record, one view is conclusively taken by AO, it would not be open for the AO to reopen the assessment based on the very same material and take another view.
Rameshkumar Tagraji Jain Vs ITO (ITAT Mumbai) It is noted that the assessee during the first appellate proceeding before Ld. CIT(A) had filed the written submission mainly assailing the validity of the action of the AO to have framed the reassessment order without issuance of mandatory notice u/s 143(2) of the Act and cited the […]
PCIT from whom approval has been taken is not specified authority for approval under Section 148 and Section 148A of Income Tax Act, 1961.
HC find no substance in AO’s reason to believe that income chargeable to tax has escaped assessment in as much as there is no mention of any tangible material that led to his conclusion. The entire process is triggered on a change of opinion as to the calculation of tax payable by the assessee.
Presumption that Petitioner beneficiary of accommodation entries based on statement of third party was disproved. Consequently, onus would be on AO to provide reasons to disbelieve bank statements and supporting documents for reopening the assessment.
Rupa Mahesh Gandhi Vs ITO (ITAT Ahmedabad) As transpires from the orders of the authorities below, the addition to the income of the assessee on account of unexplained investment in Bombay Stock Exchange of Rs.25,21,525/- and unexplained source of payment of credit card amounting to Rs.3,45,000/- was made in the absence of any details submitted […]
Section 148A(b) Notice is not expected to be as detailed as assessment order and it would suffice that reassessment reasons broadly outlined
ITAT held that co-owners showed capital gains of different amount, is not a valid ground for issue of notice under section 148
Before issuance of notice under Section 148 of the Act, approval of the higher authorities is a mandatory statutory requirement.
HC held that issuance of a notice under Section 148 in absence of any new tangible material was nothing but an attempt to review earlier order of assessment passed by A.O.
