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...
If foundational allegation is missing in notice issued under Section 148A(b) , the same cannot be incorporated by issuing a supplementary notice.
Geeta Agarwal Wife Of Shri Navratan Agarwal Vs ITO (Rajasthan High Court) It is contended that as in the present case, the income, which is alleged to have escaped assessment, is far below Rs.50 lacs i.e., Rs.8 lacs, the bar under clause (a), sub-section (1) of Section 149 of the Act would come into play […]
Ester Industries Ltd Vs ACIT (Delhi High Court) High Court is of the view that the condition precedent of an asset in the form of Rs.50 lakhs is not be attracted to the present case, as the notice under Section 148A(b) of the Act had been issued on 17th March, 2022 i.e. within three years […]
Reassessment was bad in law beyond four years when the tax payer had disclosed the facts at the time of original assessment proceedings and the AO did not draw any adverse inference regarding the same.
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 […]
