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Apex Court in its recent judgment put quietus to one of the largely litigated issue on validity of notices issued under section 148 of Income Tax Act between the period 01.04.2021 to 30.06.2021.
Reassessment notice under Section 148 of IT Act i.e, impugned notice if carried to its logical end, in the facts and circumstances of the case, will clearly neutralize all these arguments and the writ petitioner assessee bank will not be aggrieved in any manner.
Shri Jaideep Singh Vs ITO (ITAT Jaipur) A question that arises for con sideration is whether the AO can issue second notice u/s 148 and initiate fresh reassessment proceedings before completion/conclusion of proceedings initiated by way of first notice u/s 148 either by way of dropping the first reassessment proceedings or completing the proceedings by […]
Valco Industries Ltd Vs ACIT (ITAT Chandigarh) Facts- The assessee originally filed return declaring total income of Rs.4,83,83,620/- on 28.09.2012 after claiming deduction of Rs.5,75,64,789/- u/s 80IC of the Act. The assessment was completed u/s 143(3) of the Act on 27.03.2015 at an income of Rs.8,07,03,620/- after making an addition of Rs.3,23,20,000/- on account of […]
Section 56 of the U.P. VAT Act would reveal that the section has wide power, but seeking of permission by the assessing authority for making reassessment of the dealer is not conferred under the said provision.
Manash Nandi Vs ITO (ITAT Kolkata) We find that the AO has recorded the reasons u/s 148 of the Act in a very casual manner. We find that the AO has only reproduced in the reasons recorded the information received and hurriedly came to the conclusion that there exists escapement of income and evasion of […]
Explore the mind-bending time travel concept of Avengers Endgame visualized through the lens of the Income Tax Act.
Change of opinion does not constitute justification and/or reason to believe that income chargeable to tax has escaped assessment.
ITAT Delhi held that Reopening not allowable to disallow prior period expenses which were duly disclosed during original Assessment in Financial Statements and Tax Audit report
Re-opening proposed is purely based on change of opinion and entire issue which is subject matter of reasons recorded has been raised during assessment proceedings
