Income Tax : Understand the statutory time limits for issuing income-tax notices and completing assessments under the Income-tax Act. The guide...
Income Tax : This article explains why reassessment proceedings may be invalid if the Assessing Officer merely relies on Investigation Wing rep...
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 : 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 : Bombay HC upheld ITAT's order, holding reassessment under Section 148 unsustainable as full reasons were not supplied and relied o...
Income Tax : The Bombay High Court held that reassessment proceedings for AY 2018-19 were invalid because the sanction was granted by the PCIT ...
Income Tax : The ITAT held that reassessment notices issued after the surviving limitation period prescribed by the Supreme Court were invalid....
Income Tax : The Gujarat High Court held that reassessment cannot be sustained merely because of high-value bank transactions without evidence ...
Income Tax : ITAT Pune held that reassessment proceedings were invalid because the approval under Section 151 was granted by the Principal Comm...
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...
Tek Chand Vs ITO (ITAT Chandigarh) The A.O. obtained the approval of the PR. CIT before issuing the notice under section 148 of the Act. The proposal dt. 11/03/2016 seeking the approval for issuance of notice under section 148 of the Act, by the A.O. is placed at page no. 2 & 3 of the […]
Purshottambhai Bachubhai Pitroda Vs DCIT (Gujarat high court) Thus, on receipt of the reasons, the noticee is entitled to file his objections and the Assessing Officer, in turn, is obliged to dispose of the objections by passing a speaking order. Though the Assessing Officer had an opportunity at the stage of dealing with the objections […]
Which functionality is to be used for uploading the information in respect of cases where the income escaping assessment pertains to AYs 2013-14 to 2017-18 as mentioned in Para 2(a) of the aforementioned directions issued vide F.No.414/132/2018-IT(Inv.I)(Part I) dated 5th March, 2021?
CBDT directs that following categories of cases be considered as ‘potential cases’ for taking action u/s 148 of Act by 31.03.2021 for the A.Y 2013-14 to A.Y 2017-18 by Jurisdictional Assessing Officer
According to Mr. Mahna, the administrative approval of Principal Chief Commissioner, Income Tax was obtained by the Assistant Commissioner, Income Tax only on 30.03.2018, i.e., after the issuance of the notice under Section 148 of the Act.
Luxe Trading And Holding (India) Pvt. Ltd. Vs ITO (ITAT Delhi) From a perusal of the reasons, it is seen that the notice u/s. 148 of the Act has been issued mechanically without application of mind and the satisfaction by the Assessing Officer is only the borrowed satisfaction of the Investigation Wing. The Assessing Officer, […]
We are of the view that the AO has re-opened the assessment on mere change of opinion, because it is the assessing officer who took a different view at the time of reopening of assessment, i.e., he has entertained an opinion that the family members should have transferred the gold to the assessee firm and then the assessee firm should have held the gold on its own account.
Kasapu Ramesh Babu Vs ITO (ITAT Visakhapatnam) Assessing Officer has to act on the basis of “reasons to believe” and not on “reasons to suspect”. In the instant case, the initiation of proceedings u/s 147 of the Act are based upon no evidence and/or un-corroborative material. The Assessing Officer further failed to establish the nexus […]
Harmeet Singh Vs ITO (ITAT Delhi) At the time of hearing, Ld. Counsel of the assessee has only argued the legal ground and stated that the reopening action of the AO and confirmation thereof by the Ld. CIT(A) is in violation of mandatory jurisdictional conditions stipulated under the Act. It was further stated that the […]
Reassessment by AO was justified as it could not be said that there was no material before AO to reopen the assessment and he proceeded mechanically based on the sole information received from the Investigation Wing and the impugned notice was without jurisdiction and contrary to Section 147.
