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Income Tax : A detailed look at how the Finance Act, 2021 reshaped Sections 147–151, introduced Section 148A, and reduced limitation periods ...
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Income Tax : The issue was whether reassessment could be initiated after four years without fresh evidence. The court held such reopening inval...
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The Court held that Section 148 notices dated 31 March 2021 but issued after that date could not be treated as issued within the old limitation period. The ruling applies the amended reassessment framework and the Supreme Court’s directions in similar cases.
The Tribunal noted that the Assessing Officers communication did not consider the assessees objections but only reiterated the basis of reopening. As the objections were not disposed of through a separate speaking order, the reassessment lacked jurisdiction. The ruling underscores that non-compliance with GKN Driveshafts cannot be treated as a mere procedural lapse.
The Tribunal held that notices under section 153C issued without independent satisfaction by the AO are invalid, quashing the consequent assessments for AY 2018-19 to 2020-21.
The Tribunal held that reopening the assessment on the same grounds already examined in the original scrutiny amounted to an impermissible change of opinion. With no new material on record, the reassessment was found invalid. The ruling reinforces that the AO cannot revisit an earlier view in the guise of section 147 proceedings.
The ITAT held that reassessment notices under section 148 issued to a deceased person are invalid, emphasizing that such notices cannot confer jurisdiction and proceedings are void ab initio.
The ITAT annulled the entire reassessment because the Section 148 notice was issued after the Supreme Court–mandated surviving-period cutoff. The ruling confirms that any notice beyond this timeline is void ab initio.
Tribunal clarified that mere generation or digital signing on ITBA does not mean a notice is issued. Proper dispatch to the assessee’s email or portal before the statutory deadline is required for validity.
ITAT held that a 147 reopening based on the incorrect assumption that no return was filed is invalid. Since the assessee proved the return was filed, the entire reassessment was quashed.
The Tribunal ruled that reopening based solely on an Insight Portal flag without independent verification is invalid. It held that absence of tangible material and incorrect factual assumptions renders the entire 147 proceeding void.
ITAT held that reassessment notices issued beyond three years require approval from PCCIT/PDGIT, not PCIT. The invalid sanction vitiated all proceedings, following Rajeev Bansal.
