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...
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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 Bombay High Court held that sanction under Section 151(i) instead of Section 151(ii) for AYs 2016-17 and 2017-18 rendered reassessment notices invalid. It also quashed the consequential assessment orders and demand notices.
This article explains why reassessment proceedings may be invalid if the Assessing Officer merely relies on Investigation Wing reports or Insight Portal information without forming an independent opinion. It highlights the importance of challenging jurisdiction before arguing the merits.
The Supreme Court directed High Courts to first determine whether the reassessment cases relate to AY 2015-16. If they do, the notices must be declared time-barred in terms of Rajeev Bansal without further adjudication.
The Gujarat High Court held that the reassessment notice issued under the new regime was time-barred as it was issued after the surviving limitation period prescribed under TOLA and interpreted by the Supreme Court. The notice, order under Section 148A(d), and consequential proceedings were quashed.
ITAT Chennai condoned a 311-day delay in filing the appeal and restored the matter for fresh adjudication. The Tribunal held that the assessee should receive one final opportunity to explain the source of cash deposits with supporting documents.
The Delhi ITAT held that reassessment proceedings were invalid where the Assessing Officer made additions unrelated to the reasons initially recorded for reopening. The consequential penalty proceedings were also set aside.
The Delhi ITAT held that reassessment notices issued beyond four years were invalid as the Assessing Officer failed to record the assessee’s alleged failure to make full and true disclosure. The addition relating to ₹13.10 crore share application money was consequently set aside.
The ITAT held that reassessment initiated beyond four years cannot survive unless the Assessing Officer records that the assessee failed to fully and truly disclose material facts. Since the recorded reasons contained no such allegation, the notice under Section 148 was declared invalid. The consequential reassessment order was quashed.
The High Court questioned the Revenue’s refusal to grant credit for advance tax and TDS despite substantial amounts already lying with the Government. The matter was directed towards reconsideration through a fresh assessment.
SC dismissed Revenue’s plea after Gujarat HC held that even proposed additions would not alter MAT liability, defeating escapement claims. HC found all material facts were disclosed during scrutiny assessment; SC left the order undisturbed.
