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...
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...
Income Tax : Explore legality of Section 148A(b) & Section 148A(d) proceedings post Finance Act 2021. Understand implications of local assessm...
Income Tax : In a recent case, Madras High Court rules on reassessment proceedings against a struck-off company, highlighting the need for rev...
Income Tax : Understand the critical role of the initial enquiry under Section 148A(a) for taxpayer protection in income tax assessments. Explo...
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 : Under the provisions of Income-tax Act, 1961, notices for assessment/reassessment of income of old cases of more than six years fr...
Income Tax : PCIT Vs Farmson Pharmaceuticals Gujarat Pvt Ltd (Gujarat High Court): Reassessment cannot be solely based on a reevaluation of exi...
Income Tax : Himachal Pradesh High Court quashes reassessment notice for J.B.J. Perfumes Pvt. Ltd. based on 'Change of Opinion'. Learn about th...
Income Tax : Analysis of Swarn Singh Vs ITO (ITAT Amritsar) on validity of notice u/s 148 by Jurisdictional Assessing Officer (JAO) vs Faceless...
Income Tax : Learn why a reassessment notice issued under Section 148 beyond the four-year period from the end of the relevant assessment year ...
Income Tax : Reassessment proceedings initiated by officers without jurisdiction and completed by different officers without recording fresh re...
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...
Income Tax : Salient features of new Section 148 to 151A 'i.e. assessment/reassessment procedure of Income Escaping Assessment...
SPR & RG constructions Pvt. Ltd. Vs ACIT (ITAT Chennai) The issue under consideration is whether the reasons for reopening of assessment u/s 147 are justified? The reasons recorded for reopening are on the basis of the audited accounts of the assessee i.e., specifically perusal of Schedule 30 of the profit and loss account and […]
Presently, notice u/s 143(2) is generated by CASS in ITBA. Also, AO issues the statutory notice including notice u/s 142(1) with Questionnaire of the IT Act 1961 from the ITBA assessment module to the assessee’s designated email ID. Similarly, there are many proceedings of the Income Tax Act which require notice or correspondence between the Department and taxpayer and vice-versa including proceedings for appeal, exemption, rectification etc.
Anand Developers challenges IT Act notice for Assessment Year 2012-13. Jurisdictional issues, disclosures, and reopening examined by Bombay to Goa High Court.
Reopening of assessment was justified in case of EDPL as there were sufficient ‘reasons to believe’ that income had escaped assessment and the bar to reopening of proceedings after expiry of four years from the date of final assessment order, under the proviso, did not apply in assessee’s case and there was no requirement to issue two separate notices in the name of amalgamated company (i) as successor-in-interest of the amalgamating company and (ii) in its individual capacity as EDIPL had ceased to exist as a separate entity.
Price Waterhouse & Co. Vs DCIT (ITAT Kolkata) Conclusion: Since the addition on basis for which AO reopened assessment had already been disclosed by assessee in the return of income filed by him u/s 139(1), AO having not carried out the scrutiny assessment within the prescribed statutory limit, could not be given another innings for […]
The issue under consideration is whether the re-opening of assessment is justified if it is based on the similar issues and evidences which have been already considered in original assessment?
Many times in Reassessment proceedings very little importance & attention is paid to the timing of issue of notice under section 143(2). Section 143 of Income Tax Act is about Assessment, subsection 2 of section 143 talks about issue of notice in cases where return of income has been filed within the time limits specified […]
Section 148 stands for reassessment or income escaping assessment. Nowadays income tax department is scrutinizing more returns under Section 148 of the Income Tax Act. So we are here to discuss about section 148 of the Income Tax Act, 1961. Article explains Time limit for issuance of notice u/s 148, Issuance of show cause notice […]
In such cases, assessments can be reopened only if an income assessable to tax has escaped on account of failure of the assessee to disclose all the material facts fully and truly. In other words, the AO has to demonstrate that income of the assessee has escaped assessment on account of its failure to disclose all material facts of the assessments in its income fully and truly.
In the given case, the Petitioner who is a regular income tax assessee filed her return of income for the AY 2011-12. The Assessing Officer issued under section 133(6) of the Act, called for certain information from the assessee.
