Income Tax : Understand the statutory time limits for issuing income-tax notices and completing assessments under the Income-tax Act. The guide...
Income Tax : This article explains why reassessment proceedings may be invalid if the Assessing Officer merely relies on Investigation Wing rep...
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 : 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 : Bombay HC upheld ITAT's order, holding reassessment under Section 148 unsustainable as full reasons were not supplied and relied o...
Income Tax : The Bombay High Court held that reassessment proceedings for AY 2018-19 were invalid because the sanction was granted by the PCIT ...
Income Tax : The ITAT held that reassessment notices issued after the surviving limitation period prescribed by the Supreme Court were invalid....
Income Tax : The Gujarat High Court held that reassessment cannot be sustained merely because of high-value bank transactions without evidence ...
Income Tax : ITAT Pune held that reassessment proceedings were invalid because the approval under Section 151 was granted by the Principal Comm...
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...
ITAT Pune held that it is an admitted fact that assessee has fully and truly disclosed all the material facts and hence initiation of re-assessment proceedings merely on the change of opinion by AO is impermissible in law.
Gujarat High Court held that details relating to share application money from the four entities was supplied by the assessee during regular assessment and AO was satisfied with the genuineness of the same Hence reopening the assessment doubting the same entries on the basis of change of opinion is unsustainable.
Delhi High Court held that reassessment proceedings cannot be initiated by mere change of opinion of the Assessing Officer regarding the question of the fair market value or whether the amount paid by the assessee to his sisters was deductible from the total consideration.
Income Tax Reassessment invalid if A.O having jurisdiction over the case of the assessee had failed to obtain the requisite sanction u/s 151 of the Act from the Pr. CIT qua his ‘reasons to believe’
Delhi high court held that there was no new/ fresh material before AO to initiate reassessment proceedings, accordingly, mere change of opinion cannot form the basis for initiating reassessment proceedings
Gujarat High Court held that change of opinion on the part of the Assessing Officer acting on the same material which was examined by him in the regular assessment is erred in law.
Agriculture Produce Market Committee Vs ITO (Bombay High Court) It is observed that reply filed by the petitioner to the notice has not been taken into consideration especially in view of the fact that such reply was filed on 31.03.2022 and on the same day the impugned order came to be passed on 10.41 p.m. […]
Pramod Kumar Vs ACIT (Telangana High Court) HC is of the view that present is not a fit case to interdict the proceedings at the very threshold. Reasons have been assigned by the assessing officer as to why the explanation given by the petitioner could not be accepted. Certainly, such reasons given have a nexus […]
Ratnagiri Gas And Power Private Limited Vs ACIT (Delhi High Court) A perusal of the paper book reveals that the petitioner’s responses dated 13th June, 2022, and 30th June, 2022, have not been considered by the AO while passing the impugned order under Section 148A(d) of the Act. 11. Consequently, the impugned order passed under […]
Re-assessment proceedings were sought to be initiated against a non-existent company as it had amalgamated with Petitioner and income of assessee had already been accounted for in books of accounts of Petitioner.
