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 ITAT ruled the reassessment void because the AO failed to verify Insight data against the taxpayer’s filed return, leading to a factual mismatch and generic reasons for reopening. The decision confirms that mechanical satisfaction based on unverified information lacks the “live link” required for a valid Section 147 jurisdiction.
ITAT Mumbai held that reassessment orders issued outside the Faceless Scheme and without a valid DIN were void ab initio, striking down additions under Sections 69A/69B.
Mumbai ITAT deleted a ₹4.20 lakh addition, quashing the reassessment because the addition was based solely on uncorroborated, retracted search statements and “dumb documents.” The tribunal ruled that once retracted, statements lose evidentiary value without independent verification.
ITAT Delhi quashed reassessment proceedings for AY 2013-14 and 2015-16, ruling that notices issued after the extended final deadline of June 24, 2022, were time-barred under Section 149, following the Rajeev Bansal ruling.
The Delhi ITAT invalidated a reassessment, ruling the AO failed to establish independent ‘reason to believe’ and merely borrowed satisfaction from an Investigation Wing report without tangible material or a live link to the assessee’s income. This judgment establishes that reassessment cannot be based solely on second-hand, non-incriminating information from a third-party search.
The ITAT Pune ruled that a reassessment initiated under sec.147/148, even for non-filers who later filed a return, is void ab initio if the mandatory 143(2) notice is not issued. The Tribunal set aside the cash deposit addition and remanded the matter for fresh adjudication, reinforcing that 143(2) notice is a jurisdictional requirement.
Judicial precedent from Karnataka HC confirms that Assessing Officer must provide not less than seven days to an assessee to respond to a show-cause notice under Section 148A(b). Failure to comply renders the notice and all subsequent reassessment steps, including the order and penalty notice, invalid.
ITAT Mumbai held that reopening of assessment under Section 147 of the Income Tax Act is invalid if based on no new tangible material. The order clarified that such reopening is legally unsustainable and liable to be quashed.
The ITAT Mumbai set aside a reassessment for A.Y. 2017-18, ruling that the mandatory prior approval for a notice issued after three years must come from the PCCIT, not the PCIT. Citing Bombay HC precedents, the Tribunal deemed the order a legal nullity.
Delhi High Court quashes reassessment for AY 2016-17 in Kusum Healthcare Pvt. Ltd. vs DCIT, holding sanction by PCIT invalid under Section 151 of the Income Tax Act.
