Income Tax : Learn about Income Tax Act Section 147 assessment proceedings: reasons for reopening, notice issuance, objections, assessment proc...
Income Tax : Under Section 147 of the Income Tax Act, reassessment cannot be based on a mere change of opinion by the AO. Read more on this leg...
Income Tax : Explore the Bombay High Court's decision on reassessment under Section 147, balancing tax authority powers with procedural safegua...
Income Tax : SC clarifies reassessment notices under TOLA and Finance Act 2021 in Union of India v. Rajeev Bansal. Learn how decision impacts t...
Income Tax : Explore the Supreme Court's impact on India's tax reassessment system, highlighting judicial intervention, tax administration, and...
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 : Rajasthan HC allows partial relief in reassessment dispute, directing a 20% deposit for stay on demand recovery while cases awai...
Income Tax : Calcutta HC dismisses IT department's appeal in CIT vs. Infinity Infotech, ruling reassessment cannot expand beyond recorded reaso...
Income Tax : Aadhunik Infrastructure Development Pvt. Ltd. Vs DCIT (ITAT Pune) The Income Tax Appellate Tribunal (ITAT), Pune Bench “A,” ha...
Income Tax : ITAT Kolkata invalidates reassessment of Neena Commercial Pvt. Ltd. due to vague reasons and lack of jurisdiction for new addition...
Income Tax : Punjab & Haryana HC quashes Section 148 notice issued by jurisdictional AO, ruling that only NFAC has authority under CBDT Circula...
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...
Shri Ram Mohan Rawat Vs ITO (ITAT Jaipur) Reasons recorded by the AO for formation of belief that income assessable to tax has escaped assessment are based on two counts. One, the assessee has made bogus purchases and the second, that the purchases are not verifiable as the as the assessee has not filed the […]
The issue under consideration is whether Non-furnishing of reasons recorded for reopening of assessment made the entire assessment u/s 147 invalid in law?
The CBDT on 12th September 2019, notified the much talked about e-assessment procedure vide Notification no. 61/2019. The stakes were high, as it was expected to reduce the red-tapism in the country, during an assessment proceeding. This notification was quickly followed up by another notification vide 62/2019, giving effect to the Income Tax E-Assessment Scheme, […]
[Notification No. 62/2019 For giving effect to the E-assessment Scheme, 2019 the Central Government hereby makes the following directions
The assessment under E-assessment Scheme, 2019 shall be made as per the following procedure, namely (i) the National e-Assessment Centre shall serve a notice on the assessee under sub-section (2) of section 143, specifying the issues for selection of his case for assessment;
Satish Kumar Vs ITO (ITAT Delhi) It is an admitted fact that assessee filed reply in response to the notice under section 148 of the I.T. Act and submitted before A.O. that original return filed before him may be treated as return filed in response to the notice under section 148 of the I.T. Act. […]
Reopening of assessment u/s 147 of the IT Act , 1961 on the basis of information from Investigation Wing of the department On the basis of information received from the investigation wing of the department, the Assessing officer cannot issue notice u/s 148 of the act mechanically, without using his own mind. He has to […]
The assessee had challenged reopening of assessment on two grounds. The CIT(A) had accepted the arguments of the assessee, in light of provisions of section 147 of the Act, and the assessment order passed by the AO u/s 143(3) of the Act, dated 29/12/2018 and came to the conclusion that the assessment has been reopened on change of opinion without there being any tangible material, in the possession of the AO, which suggest escapement of income.
M/s. Neelkanth Plywood Pvt. Ltd. Vs Income Tax Officer (ITAT Delhi) A perusal of the reasons for reopening of the case for the impugned assessment year, copy of which is placed at paper book page No. 20-21 shows that the reopening was made on the basis of the report of the investigation wing and there […]
Though AO had issued notice under section 148 on 26-3-2014, i.e., within period of six years from the end of relevant assessment year, however, it was returned unserved by postal authorities and even notice by affixture was also served on 4-4-2014 and there was no report of AO containing names and addresses of witnesses having identified the property, therefore, in the absence of section 148 notice served within stipulated period, reassessment proceedings were invalid.
