Income Tax : Explore the Bombay High Court's ruling on the invalidity of a reassessment notice under Section 148 of the Income-tax Act, 1961, f...
Income Tax : Learn about Section 147 to 153 Income Escaping Assessment and Reopening of Cases Under Income Tax Act, 1961. Get guidance on the p...
Income Tax : Explore legality of Section 148A(b) & Section 148A(d) proceedings post Finance Act 2021. Understand implications of local assessm...
Income Tax : In a recent case, Madras High Court rules on reassessment proceedings against a struck-off company, highlighting the need for rev...
Income Tax : Understand the critical role of the initial enquiry under Section 148A(a) for taxpayer protection in income tax assessments. Explo...
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 : Under the provisions of Income-tax Act, 1961, notices for assessment/reassessment of income of old cases of more than six years fr...
Income Tax : PCIT Vs Farmson Pharmaceuticals Gujarat Pvt Ltd (Gujarat High Court): Reassessment cannot be solely based on a reevaluation of exi...
Income Tax : Himachal Pradesh High Court quashes reassessment notice for J.B.J. Perfumes Pvt. Ltd. based on 'Change of Opinion'. Learn about th...
Income Tax : Analysis of Swarn Singh Vs ITO (ITAT Amritsar) on validity of notice u/s 148 by Jurisdictional Assessing Officer (JAO) vs Faceless...
Income Tax : Learn why a reassessment notice issued under Section 148 beyond the four-year period from the end of the relevant assessment year ...
Income Tax : Reassessment proceedings initiated by officers without jurisdiction and completed by different officers without recording fresh re...
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...
Hitech Outsourcing Services Vs CIT (Gujarat High Court) We have noticed that the Assessing Officer in teh original assessment proceedings had examined the assessee’s claim of deduction under section 10B of the Act. It is not as if such claim went unnoticed or unscrutinized. He wanted to be specific about the assessee’s claim for deduction […]
There was no new tangible material evidence brought on record by AO. Assessment was reopened only on the basis of details available on record and wrongly interpreted by AO.
The issue under consideration is whether the addition made by AO u/s 68 of Income tax Act, 1961 is justified in law?
Income Tax Act, 1961 contains different time limits for issuance of notice, filing of application, completion of assessments, passing of penalty order under several sections. Hence, for the ease of reference for professionals and students
PCIT v. M/S Broadway Shoe Co. (Jammu & Kashmir High Court) Admittedly in the instant case, the return was filed by the assessee after the time prescribed for filing return under Sections 139(1) and 139(4) had expired. Therefore, the return filed by the assessee has to be treated as non-est. The proceedings under Section 147 of […]
PCIT Vs Inarco Limited (Bombay High Court) The grievance of the Revenue before us is that the Assessing Officer omitted to consider Section 50C of the Act while passing the order dated 26.12.2007 under Section 143(3) of the Act. Thus, it is submitted that the reopening notice dated 11.3.2010 is valid in law. In this […]
Vikram Singh Vs CIT (Allahabad High Court) The only contention raised by the learned counsel for the appellant-assessee is that the notice was not issued with the prior sanction of the Joint Commissioner, but sanction was accorded by the Additional Commissioner and, therefore, notice under Section 148 of the Act issued by the A.O. was […]
Siddhi Vinayak Aeromatics (P) Ltd. Vs ACIT (ITAT Delhi) In this case Assessee had filed complete details as required during assessment proceedings and after complete verification of the details assessment was framed by AO under section 153/143(3) of Income Tax Act, 1961. AO had not produced any tangible material that there was failure on the […]
Where the JCIT/ACIT has only recorded Yes I am satsfied then, it has to be held that the approving authority has recorded satisfaction in a mechanical manner and without application of mind to accord sanction for issuing notice u/s. 148 of the Act for reopening of assessment and in this situation initiation of reassessment proceedings and reopening of assessment has to be held as invalid and bad in law.
Sonia Gandhi & Oscar Fernandes Vs. ACIT and Rahul Gandhi Vs. PCIT (Delhi High Court) The entire premise of the reassessment notices in this case is that the nondisclosure of the taxing event, i.e. allotment of shares (and the absence of any declaration as to value) deprived the AO of the opportunity to look into […]
