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 : The High Court held that reassessment proceedings for AY 2013-14 were time-barred after computing the surviving limitation as clar...
Income Tax : A detailed look at how the Finance Act, 2021 reshaped Sections 147–151, introduced Section 148A, and reduced limitation periods ...
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 : ITAT Delhi held reassessment orders invalid because the assessee was not supplied with the recorded reasons for reopening under Se...
Income Tax : The Supreme Court dismissed the challenge to a Delhi High Court ruling that quashed reassessment proceedings under Sections 148A(d...
Income Tax : The Telangana High Court held that reassessment proceedings initiated by the Jurisdictional Assessing Officer after implementation...
Income Tax : Gujarat HC held that reassessment under Sections 147 and 148 was valid where Assessing Officer received fresh investigation materi...
Income Tax : The Delhi High Court held that reassessment proceedings under Section 148 were invalid where the Assessing Officer sought to make ...
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...
Bombay High Court held that reopening of assessment under section 148 in absence of any new information received by AO between the date of assessment order u/s 143(3) till the issuance of notice u/s 148 is unjustified and untenable in law.
HC quashed section 148 notice issued without sufficient reasons to initiate reassessment proceedings without satisfying conditions precedent under Section 147
Bombay High Court held that reopening of assessment in absence of failure on the part of the assessee to disclose fully and truly the material facts and also in absence of any tangible material is unjustifiable.
Revenue Department could only re-open an assessment beyond four years, if there was a failure on the part of assessee to disclose material facts fully and truly and not on the basis of reason to believe without satisfying jurisdictional condition required under provisions of Section 147
If foundational allegation is missing in notice issued under Section 148A(b), the same cannot be incorporated by issuing a supplementary notice.
Bombay High Court held that issue of reopening of assessment has to be tested only on the basis of the reasons recorded, which reasons can neither be improved upon nor substituted by an affidavit or oral submissions.
If there is no valid service of notice under section 148, the reassessment proceedings are null and void. service of notice under section 148 is a condition precedent for making reassessment or re-computation under section 147 of the Act.
Rajendra Bana Vs ITO (Rajasthan High Court) Shri Vedant Agarwal, learned counsel representing the petitioner drew the Court’s attention to the order dated 11.10.2022 passed by Division Bench of this Court at Jaipur in D.B. Civil Writ Petition No.14794/2022 and urged that the impugned notice whereby, the re-assessment proceedings have been opened against the petitioner, […]
Learn how section 147/148 of the Income Tax Act gives plenary powers to reopen concluded assessments. Find out why ‘Reasons to Believe’ is the foundation stone of proceedings u/s 147/148 and what makes it different from ‘Reason to Suspect’
Once claim has been allowed in scrutiny proceedings, then AO cannot withdraw the claim under section 154, by mere change of opinion and without there being any apparent mistake on record.
