Income Tax : Understand the statutory time limits for issuing income-tax notices and completing assessments under the Income-tax Act. The guide...
Income Tax : This article explains why reassessment proceedings may be invalid if the Assessing Officer merely relies on Investigation Wing rep...
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 : 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 : Bombay HC upheld ITAT's order, holding reassessment under Section 148 unsustainable as full reasons were not supplied and relied o...
Income Tax : The Bombay High Court held that reassessment proceedings for AY 2018-19 were invalid because the sanction was granted by the PCIT ...
Income Tax : The ITAT held that reassessment notices issued after the surviving limitation period prescribed by the Supreme Court were invalid....
Income Tax : The Gujarat High Court held that reassessment cannot be sustained merely because of high-value bank transactions without evidence ...
Income Tax : ITAT Pune held that reassessment proceedings were invalid because the approval under Section 151 was granted by the Principal Comm...
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...
The Tribunal held that reassessment proceedings fail when the foundational assumption behind reopening is factually incorrect. It ruled that “reasons to believe” must exist in reality at the time of recording, failing which the entire reassessment becomes void ab initio.
The Court reaffirmed that both JAO and FAO can validly initiate reassessment proceedings, notwithstanding contrary High Court views elsewhere.
The Tribunal examined whether reassessment could stand when based on information relating to another individual. It held that reopening was invalid due to absence of any tangible material against the assessee.
ITAT Mumbai (E Bench) in Estate of Vandravan P. Shah vs ACIT (ITA Nos. 5401, 5402 & 5403/Mum/2024; AYs 2011-12, 2012-13 & 2017-18; order dated 23.12.2025) has partly rejected the assessee’s jurisdictional challenge and upheld the validity of reassessment proceedings initiated and completed in the name of the deceased through legal representative u/s 159, while also sustaining the disallowance of deduction u/s 35AC on alleged bogus donation to Navjeevan Charitable Trust.
The Tribunal struck down reopening where reasons conflicted and rested solely on AIR cash-deposit data. The key takeaway is that reassessment needs a clear, reasoned nexus.
The issue was whether the Assessing Officer could alter income despite a valid APA and modified return. The Court held that without an adverse TPO audit or APA cancellation, reassessment adjustments were without jurisdiction.
ITAT held that section 69 cannot be invoked where purchases are duly recorded in books and paid through banking channels, making the reassessment unsustainable.
ITO Vs Srichand Mandhyan (Supreme Court of India) Supreme Court considered a Special Leave Petition challenging an order passed by the Bombay High Court. After hearing the learned counsel for the parties and examining the material on record, the Supreme Court found no valid ground to interfere with the High Court’s decision. Accordingly, the Special […]
Bombay HC held that reassessment notices issued with sanction under an incorrect statutory provision are invalid, leading to quashing of notices, assessments, and consequential demands.
The Tribunal ruled that the amended reassessment law does not revive assessment years that had become time-barred under the earlier statutory provisions.