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...
The High Court held that notices issued under Section 148 by a jurisdictional Assessing Officer were without authority when the faceless assessment scheme applied. Relying on binding precedents, the writ petition was disposed of in favour of the taxpayer, reaffirming NFAC’s exclusive role.
The court held that an excel sheet found during a search, indicating a cash transaction, constituted valid information to reopen assessment.
The issue was whether an assessment could be reopened after four years. The Court held that full disclosure by the taxpayer barred reassessment under Section 147.
Gattula Lakshmi Madhavi Vs ACIT (ITAT Visakhapatnam) Central Circle Cannot Assume Reassessment Powers — Section 148 Notice Issued Outside Faceless Regime Held Void The Visakhapatnam Bench of the ITAT quashed the reassessment framed under Section 147 and consequential penalties under Sections 270A and 271AAC in the case of Gattula Lakshmi Madhavi v. ACIT, holding that […]
The Tribunal held that reassessment proceedings fail when the foundational assumption behind reopening is factually incorrect. It ruled that “reasons to believe” must exist in reality at the time of recording, failing which the entire reassessment becomes void ab initio.
The Court reaffirmed that both JAO and FAO can validly initiate reassessment proceedings, notwithstanding contrary High Court views elsewhere.
The Tribunal examined whether reassessment could stand when based on information relating to another individual. It held that reopening was invalid due to absence of any tangible material against the assessee.
ITAT Mumbai (E Bench) in Estate of Vandravan P. Shah vs ACIT (ITA Nos. 5401, 5402 & 5403/Mum/2024; AYs 2011-12, 2012-13 & 2017-18; order dated 23.12.2025) has partly rejected the assessee’s jurisdictional challenge and upheld the validity of reassessment proceedings initiated and completed in the name of the deceased through legal representative u/s 159, while also sustaining the disallowance of deduction u/s 35AC on alleged bogus donation to Navjeevan Charitable Trust.
The Tribunal struck down reopening where reasons conflicted and rested solely on AIR cash-deposit data. The key takeaway is that reassessment needs a clear, reasoned nexus.
The issue was whether the Assessing Officer could alter income despite a valid APA and modified return. The Court held that without an adverse TPO audit or APA cancellation, reassessment adjustments were without jurisdiction.
