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 : The High Court held that reassessment proceedings for AY 2013-14 were time-barred after computing the surviving limitation as clar...
Income Tax : A detailed look at how the Finance Act, 2021 reshaped Sections 147–151, introduced Section 148A, and reduced limitation periods ...
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 : The Madras High Court held that reassessment notices required to be issued by the Faceless Assessing Officer are invalid if issued...
Income Tax : ITAT Delhi held reassessment orders invalid because the assessee was not supplied with the recorded reasons for reopening under Se...
Income Tax : The Supreme Court dismissed the challenge to a Delhi High Court ruling that quashed reassessment proceedings under Sections 148A(d...
Income Tax : The Telangana High Court held that reassessment proceedings initiated by the Jurisdictional Assessing Officer after implementation...
Income Tax : Gujarat HC held that reassessment under Sections 147 and 148 was valid where Assessing Officer received fresh investigation materi...
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...
Ashika Credit Capital Limited Vs Union of India And Ors. (Calcutta High Court) Mr. Roy Chowdhury, learned advocate appearing for the Revenue was asked to produce the record to establish that the recorded reasons were existing at the time of issuance of impugned notice under Section 148 and initiation of impugned assessment proceeding under Section […]
P. Divagar Vs ITO (ITAT Chennai) n the present case, the only issue for consideration is whether the reopening of assessment under section 147 of the Act is valid or not. For the sake of convenience, the reasons recorded and communicated to the assessee are reproduced as under: “The assessee filed his return of income […]
In view of Indiscriminate notices by income Tax Department without allowing reasonable time it is requested to Finance Ministry and CBDT that suitable steps should be taken so that adequate time is allowed for compliance and cases are not disposed of in a hurry, without giving adequate opportunity for the taxpayer to be heard. The […]
Lucknow CA Tax Practicioners Association has made a Representation to FM for Extension of Time Limit for Assessment cases time barring as on 31.3.22 under the Income Tax Act 1961 in view of Problems faced in completion of Reopened Assessment cases (letting time barred on 31st March 2022, Problems faced in completion of Assessment as […]
Section 144B in the Income Tax Act,1961 has been introduced in the Income-tax act by National e-Assessment Scheme. The ambitious scheme launched in August 2020 seeks to bring the much-needed reform revolution to the income tax procedure that encumbered tax filing for the common man, fostered corruption, and aided tax evasion. Before the scheme, after […]
Standard Builders Vs ACIT (ITAT Chennai) ITAT held that reopening could not be done in a mechanical manner and on a mere change of opinion. Further, in case of reopening beyond 4 years, the revenue must allege that there was failure on the part of the assessee to disclose material facts. We find that the […]
Kurz India Private Limited Vs PCIT (Delhi High Court) Appellant submits that in this case reopening is initiated on the basis of review and re-appreciation of the same material i.e. audited accounts which were subject to verification in the course of original assessment proceedings under Section 143(3) which is not permissible in law. Upon perusal […]
1. The “reasons to believe” in an income escaping assessment (section 148 read with section 147 of the Act) is one of the most important piece of document. It is the foundation stone with respect to the validity of the entire reassessment proceedings. “Reason to believe” is the document which requires careful consideration and it […]
ACIT Vs Sh. Ravi Parkash Aggarwal (ITAT Delhi) ITAT have gone through the reasons recorded. The first four lines consists of a factual information received from the DDIT (Inv.), Mumbai, the second part indicates that it has been established from the report that the assessee has taken accommodation entries and the third part consists of […]
HDFC Bank Ltd. Vs ACIT (Bombay High Court) Bombay high court exposing serious flaw in reopening under section 148 in HDFC case (significance of tangible material for formulation of valid belief , fatal impact of difference in the reasons recorded on file and reasons placed for statutory approval under section 151 etc. “30. The position […]
