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...
CIT(A) has rightly quashed the assessment because the very foundation for issuance of notice under section 148 is the approval from the competent authority, i.e. Commissioner of Income Tax, and in the absence of such, such notice is void ab initio.
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.
