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...
It is trite law, valid service of notice under section 148 of the Act is sine qua non for proceeding under section 147 of the Act. In absence of valid service of notice under section 148 of the Act, the assessment proceeding under section 147 of the Act has to be declared as invalid.
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 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.
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
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
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 […]
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.
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.
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 […]
Assessee found to be a beneficiary of accommodation entries and been instrumental in manipulating prices of several penny stock scrips on stock exchange.