Income Tax : Learn about Income Tax Act Section 147 assessment proceedings: reasons for reopening, notice issuance, objections, assessment proc...
Income Tax : Under Section 147 of the Income Tax Act, reassessment cannot be based on a mere change of opinion by the AO. Read more on this leg...
Income Tax : Explore the Bombay High Court's decision on reassessment under Section 147, balancing tax authority powers with procedural safegua...
Income Tax : SC clarifies reassessment notices under TOLA and Finance Act 2021 in Union of India v. Rajeev Bansal. Learn how decision impacts t...
Income Tax : Explore the Supreme Court's impact on India's tax reassessment system, highlighting judicial intervention, tax administration, and...
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 : Rajasthan HC allows partial relief in reassessment dispute, directing a 20% deposit for stay on demand recovery while cases awai...
Income Tax : Calcutta HC dismisses IT department's appeal in CIT vs. Infinity Infotech, ruling reassessment cannot expand beyond recorded reaso...
Income Tax : Aadhunik Infrastructure Development Pvt. Ltd. Vs DCIT (ITAT Pune) The Income Tax Appellate Tribunal (ITAT), Pune Bench “A,” ha...
Income Tax : ITAT Kolkata invalidates reassessment of Neena Commercial Pvt. Ltd. due to vague reasons and lack of jurisdiction for new addition...
Income Tax : Punjab & Haryana HC quashes Section 148 notice issued by jurisdictional AO, ruling that only NFAC has authority under CBDT Circula...
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...
Reasons, as recorded for reopening reassessment, are to be examined on a standalone basis to determine validity of section 147 proceedings
Record shows that reassessment proceedings have been triggered based on information received by respondent/revenue via a Tax Evasion Petition (TEP).
RK Gupta And Son HUF Vs ITO (Delhi High Court) HC held that notice dated 19.05.2022 issued under Section 148A(b) of the Income Tax Act, 1961 shows, that a survey report was generated vis-à-vis Varun Capital Services Ltd. The said communication also alludes to the fact that assessee had entered into share transaction with Kisna […]
PCIT Vs Karan Polymers Pvt. Ltd (Calcutta High Court) Short issue involved in the instant case is whether assumption of jurisdiction by PCIT under Section 263 of the Act was justified. The learned Tribunal noted that the issue based on which the PCIT assumed jurisdiction under Section 263 of the Act was the very same […]
Bhaveshbhai Manilal Patel Vs ITO (ITAT Ahmedabad) In this case by Information noted by the AO of cash deposits of Rs.10.00 lakhs in the bank account of the assessee leading to belief of escapement of income, has been duly demonstrated before me to be incorrect. The actual cash deposits were only to the tune of […]
Explore the amended provisions of reassessment in response to search survey by the Income Tax Department. Learn how to navigate notices under section 148, the exceptions provided in Explanation-2, and the implications for taxpayers. Stay informed with expert insights. Source: Income Tax Act 1961, Amendments, Legal Analysis.
Pankajkumar Babulal Tiwari Vs ACIT (ITAT Amhadabad) Asessee under the bona fide belief not offered income on receipt from LIC in original return however rectified the same while filing the return under section 148 of the Act. The assessee also paid due tax on such receipt even before issuance of notice under section 148 of […]
Bombay High Court held that initiation of re-assessment proceedings in violation of the procedure prescribed under section 148A(b) of the Income Tax Act i.e. without supplying requisite material is bad in law and liable to be set aside.
AO is only entitled to reopen assessment, but he cannot review an assessment in the sense that there cannot be a rethinking or different opinion on the same material, which was the subject matter of the original assessment proceedings.
ITAT Mumbai held that re-opening of assessment under section 148 of the Income Tax Act on account of mere change of opinion is bad-in-law and liable to be quashed.
