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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...
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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...
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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...
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SC dismissed Revenue’s challenge against Calcutta HC ruling that reassessment proceedings based only on suspicion and investigation reports were invalid under Section 147.
The Calcutta High Court held that reassessment proceedings cannot be reopened merely on suspicion arising from investigation reports. The Court ruled that “reason to believe” must be based on independent application of mind and material evidence.
The Income Tax Act, 2025 replaces old reassessment provisions with Sections 279 to 286 and increases reopening timelines in certain cases. Tax professionals must carefully examine applicability based on the relevant tax year.
The Supreme Court upheld the High Court ruling that approval stating fit case for reopening satisfied Section 151 requirements. The reassessment proceedings linked to alleged accommodation entries were restored.
The Supreme Court refused to interfere with the Gujarat High Court ruling quashing reassessment proceedings where the assessee had disclosed all transactions in audited accounts and income tax returns. The Court left the question of law open.
The High Court ruled that reopening based on unrelated and non-specific seized material is not permissible. It concluded that no prima facie belief of income escapement could be formed. The decision highlights limits on the use of indirect evidence.
The Supreme Court dismissed SLPs and upheld the High Court’s finding that reassessment notices lacked tangible material. The ruling reinforces that mere survey findings cannot justify reopening of assessments.
The issue was whether reassessment could be initiated after four years without fresh evidence. The court held such reopening invalid when based on existing records and no failure of disclosure.
The Court held that reassessment proceedings must be initiated within the statutory time limit. It found the notice issued after the deadline to be invalid.
ITAT Delhi held that reassessment proceedings for AY 2015-16 could not survive where the Section 148 notice was issued after 1 April 2021. The Tribunal ruled that such notices were barred by limitation and the resulting reassessment was void.
