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 : The Madras High Court held that reassessment notices required to be issued by the Faceless Assessing Officer are invalid if issued...
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 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...
Evaluate the reasonableness of Notices issued under section 148 of Income Tax Act, as amended in the Finance Act 2021. Get to know the time limits for issuing a Reassessment Notice.
ITAT Kolkata held that addition cannot be made on protective basis in the reopened assessment proceeding as the assessment cannot be reopened for a contingent nature of addition.
Auroglobal Comtrade Private Limited Vs Chairman, CBDT & Others (Orissa High Court) HC declined to accept challenge to the Reopening notices under Section 148-A(1)(b) of the Act as well as the consequential order under Section 148-A(1)(d) of the Act by holding that the Petitioners/Assessees in those cases would have a full opportunity of urging all […]
Punjab and Haryana HC rejects interference at early stage in Anshul Jain Vs PCIT case. The court holds that objections can be raised in re-assessment proceedings.
Admittedly, the issuance of notice and initiation of re-assessment proceeding are beyond six years and, prima facie, it is barred by limitation both under the old Act as well as under newly amended provision relating to Section 147 of the Act.
In present case approval has been granted by the ld. JCIT without verifying the reasons recorded by the AO for initiating the proceedings under section 147 of the Act which is contrary to the provisions of law.
AO could have taxed the accrued income or re-opened the assessment within four years. A mere incorrect claim based on full disclosures cannot be reassessed after four years by invoking sections 147 and 148 of the IT act.
HC find that the allegation of the petitioner is substantially correct in the sense that petitioner’s objection to initiation of proceeding under Section 147 and issuance of notice under Section 148 of the Act has neither been considered nor rejected.
Mumbai ITAT has quashed reopening of assessment under section 147 made by AO only on the basis of information received from report of investigation wing.
Notice under Section 148 of the Act pertaining to the Assessment Year (AY) 2013-14 was issued on 30th March 2021, i.e., prior to 1st April 2021. Also, it was beyond the period of six years after the expiry of the AY in question
