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Reassessment

Latest Articles


Bombay HC Invalidates Reassessment Notice for AY 2015-16: Lack of DIN & Jurisdictional Issue

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...

July 6, 2024 834 Views 0 comment Print

Section 147 to 153 Income Escaping Assessment (Reopening of Cases)

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...

December 10, 2023 19590 Views 7 comments Print

Validity of Section 148A(b) & Section 148A(d) Proceedings: Legal Analysis

Income Tax : Explore legality of Section 148A(b) & Section 148A(d) proceedings post Finance Act 2021. Understand implications of local assessm...

October 21, 2023 5010 Views 0 comment Print

Reassessment proceedings against struck off company invalid unless revived u/s 252 of Companies Act

Income Tax : In a recent case, Madras High Court rules on reassessment proceedings against a struck-off company, highlighting the need for rev...

October 12, 2023 1158 Views 0 comment Print

Critical Role of Initial Enquiry under Section 148A(a) for Taxpayer Protection

Income Tax : Understand the critical role of the initial enquiry under Section 148A(a) for taxpayer protection in income tax assessments. Explo...

July 12, 2023 5700 Views 0 comment Print


Latest News


Request to amend section 151 Sanctioning Authority for reassessment

Income Tax : Humble Representation for modification of Section 151 of the Income Tax Act relating to Sanction for issue of Notice under sec. 14...

July 25, 2022 6453 Views 0 comment Print

Request to clarify on SC judgement on Section 148 notices

Income Tax : Income Tax Gazetted Officers’ Association requested CBDT to issue Clarification in respect of the judgement of Hon’ble Supreme...

May 12, 2022 6936 Views 0 comment Print

Indiscriminate Income Tax notices without allowing reasonable time

Income Tax : In view of Indiscriminate notices by income Tax Department without allowing reasonable time it is requested to Finance Ministry an...

March 20, 2022 12900 Views 0 comment Print

Extend Time Limit for Income Tax Assessment time barring on 31.3.2022

Income Tax : Lucknow CA Tax Practicioners Association has made a Representation to FM for Extension of Time Limit for Assessment cases time bar...

March 20, 2022 41382 Views 2 comments Print

Notices for assessment/reassessment of income of old cases

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...

August 3, 2018 1893 Views 0 comment Print


Latest Judiciary


Reassessment cannot be based solely on reevaluating existing facts without new substantive material

Income Tax : PCIT Vs Farmson Pharmaceuticals Gujarat Pvt Ltd (Gujarat High Court): Reassessment cannot be solely based on a reevaluation of exi...

July 17, 2024 60 Views 0 comment Print

HP HC Quashes Reassessment as it was Based on ‘Change of Opinion’

Income Tax : Himachal Pradesh High Court quashes reassessment notice for J.B.J. Perfumes Pvt. Ltd. based on 'Change of Opinion'. Learn about th...

July 8, 2024 390 Views 0 comment Print

Validity of Section 148 notice by Jurisdictional AO instead of Faceless AO

Income Tax : Analysis of Swarn Singh Vs ITO (ITAT Amritsar) on validity of notice u/s 148 by Jurisdictional Assessing Officer (JAO) vs Faceless...

June 29, 2024 7137 Views 0 comment Print

Reassessment Notice Under Section 148 Invalid If Issued After Four Years

Income Tax : Learn why a reassessment notice issued under Section 148 beyond the four-year period from the end of the relevant assessment year ...

May 28, 2024 12126 Views 0 comment Print

Delhi HC Quashes Reassessment Proceedings as section 147 Notice Issued by Non-Jurisdictional Officer

Income Tax : Reassessment proceedings initiated by officers without jurisdiction and completed by different officers without recording fresh re...

May 20, 2024 1782 Views 0 comment Print


Latest Notifications


Limitation date for reopening cases related to Ashish Agarwal judgment

Income Tax : Supreme Court in the matter of Shri Ashish Agarwal, several representations were received asking for time-barring date of such cas...

February 6, 2023 5337 Views 0 comment Print

Time barring date for reopening cases arising out of SC direction

Corporate Law : Income Tax Gazetted Officers’ Association (W.B.) Unit Date: 02.02.2023. To The Principal Chief Commissioner of Income Tax, W...

February 2, 2023 2934 Views 0 comment Print

Case reopened in light of SC judgment in Ashish Agarwal to be completed by 31.05.2023

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...

January 27, 2023 14292 Views 1 comment Print

Carry out due verification before initiating Section 148/147 proceedings: CBDT

Income Tax : Consequent to order passed by Allahabad High Court passing severe strictures and proposing to levy exemplary cost of Rs 50 lakhs i...

August 22, 2022 13356 Views 0 comment Print

Revised Guideline for Issue of Section 148 Notice

Income Tax : Salient features of new Section 148 to 151A 'i.e. assessment/reassessment procedure of Income Escaping Assessment...

August 1, 2022 75150 Views 1 comment Print


Assessing Officer has no power to review & has power to re-assess

October 13, 2022 1770 Views 0 comment Print

The Assessing Officer has no power to review; he has the power to re-assess. But re-assessment has to be based on fulfillment of certain pre-condition and if the concept of ‘change of opinion’ is removed, as contended on behalf of the Department, then, in the garb of re¬opening the assessment, review would take place.

ITAT quashed Reassessment based on borrowed satisfaction & without independent application of mind 

October 8, 2022 2022 Views 0 comment Print

ITAT held that Income Tax reassessment initiated on the basis of borrowed satisfaction without any independent application of mind by Assessing Officer is liable to be quashed. 

Section 148 Notice valid If Assessee failed to submit Crypto Currency Ledger

September 20, 2022 2253 Views 0 comment Print

Assessee to satisfy the authority by submitting Crypto currency ledger to verify information as was submitted by him before AO in proceedings under Section 148A

Reassessment when Income Tax Act not provide for it – Application of Article 142

September 18, 2022 5229 Views 1 comment Print

Can the I-T department call for reassessment when the Income Tax Act, 1961 does not provide for it – Per Incuriam application of Article 142

Reopening of assessment based on Investigation Report of other Assessee justified

September 18, 2022 2157 Views 0 comment Print

S. Raheja Realty Pvt. Ltd. Vs Office of Income Tax Officer (Gujarat High Court) On perusal of the Explanation (1) of the Section 148, it is clear that that for the purpose of Section 148A, the information with the Assessing Officer which suggests that the income chargeable to tax has escaped assessment means any information […]

Reassessment is invalid in absence of valid notice

September 13, 2022 939 Views 0 comment Print

The foundation of a reassessment proceeding is a valid notice and if this notice is held to be invalid the entire edifice sought to be raised on such foundation has to collapse.

Audit Objection cannot be basis of AO’s ‘Reasons to Believe’ after lapse of time period of 6 Years

September 13, 2022 2079 Views 0 comment Print

An audit objection did not satisfy the requirement of AO having an independent ‘reason to believe’ that income had escaped assessment, that too after the elapse of nearly six years from the end of the relevant assessment year, therefore, the impugned reassessment proceedings were vitiated.

Reassessment Proceedings against Reassessment order Stayed by Delhi HC

September 13, 2022 4164 Views 0 comment Print

United Associates Vs ITO (Delhi High Court) A Writ Petition was filed in Hon’ble Delhi high Court to set aside the notice dated 28.06.2022 issued by the Income Tax Department under section 148 of the Income Tax Act, 1961 and order u/s 148A(d) issued by the Respondent No.1 under section 148 of the Income Tax […]

Penny stock/accommodation entry – Reassessment notice must contain relevant documents 

September 13, 2022 1527 Views 0 comment Print

Assessee found to be a beneficiary of accommodation entries and been instrumental in manipulating prices of several penny stock scrips on stock exchange.

Time limit for issue of section 149 notice is in respect of Section 148 & not for Section 148A

September 10, 2022 5172 Views 0 comment Print

Sylph Technologies Limited Vs Principal Chief Commissioner of Income Tax (Madhya Pradesh HC) The time limit for issue of notice under section 149 is in respect of Section 148 and not for Section 148A. 1. The AO had issued issued a notice dated 28.06.2021 under pre-amended sec. 148 of the  Income tax Act. 2. Later […]

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