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 : 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 Delhi High Court held that reassessment proceedings under Section 148 were invalid where the Assessing Officer sought to make ...
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...
Duggal Estates Pvt. Ltd. Vs ITO (ITAT Delhi) From the reasons it can be seen that the Assessing Officer was not specific as to on what basis the Assessing Officer has the reason to believe that the income of the assessee to the tune of 1 crore has escaped assessment. In fact, in one para […]
ACIT Vs. K. S. Chawla & Sons (HUF) (ITAT Delhi) > HELD THAT:- In the present assessee’s case, search & seizure action u/s 132 of the Act was carried out on 15.10.2009 in the premises of Mr. Abhinav Arora and Mrs. Ranju Arora. Consequently, the Assessing Officer initiated reassessment proceedings u/s 147 of the Act […]
Sesa Sterlite Ltd. Vs ACIT (Bombay High Court at Goa) Section 147 : Reassessment-After the expiry of four years-Shah Commission’s report- Cash credit -Under-invoicing -Merely on basis of Shah Commission’s Report opining that there was under-invoicing of export price by iron-ore miners and exporters, reassessment could not be initiated when there was nothing to indicate […]
It is open to the Court to examine whether the reasons for the formation of the belief have a rational connection with or relevant bearing on the formation of the belief and are not extraneous or irrelevant for the purpose of the section.As explained by the Hon,ble Supreme Court of India in the following judgement […]
Understanding the differences between section 147 and section 143(2) proceedings. Learn about the nuances of these tax-related legal processes.
Reopening U/S 147 Not Valid If Certain Safeguards Not Followed By Revenue As Provided In section 147,148 And 151 of Income Tax Act, 1961 The important safeguards provided in sections 147,148 and 151 has not to be treated lightly by the concerned Assessing Officer and CIT as held in Chuggamal Rajpal Vs. S.P.Challia & others […]
Reassessment made by AO in respect of assessee-bank was quashed as no new material was brought on record by AO in the reopening of assessment to establish that the income of the assessee had escaped assessment as assessee had already disclosed all the information necessary for completion of original assessment and the reopening of assessment made beyond four years from the AY under consideration.
VSR Enterprises Vs ITO (ITAT Delhi) Assessing Officer in the instant case has recorded incorrect/wrong and non-existing reasons in the reason for reopening of the assessment and has not applied his mind to the information received from REIC, Ward 43(4)(New Delhi). Therefore, the reopening of the assessment is illegal and bad in law and is […]
Simranpal Singh Suri Vs ITO (ITAT Delhi) This shows that the notice u/s 143(2) was issued to the assessee on the very same day on which the assessee appeared and furnished copy of ITR in response to notice u/s 148 of the IT Act. It has been held in various decisions that when the notice […]
When the notice u/s 143(2) was issued to assesseee on the very same day on which assessee filed the return in response to notice u/s 148 stating that the return already filed may be treated as return in response to notice u/s 148, such notice issued u/s 143(2) on the very same day had to be treated as invalid and assessment was vitiated due to non-application of mind by the AO.
