Income Tax : ITAT held that additions based solely on third-party search material without independent evidence or cross-examination are invalid...
Income Tax : A detailed look at how the Finance Act, 2021 reshaped Sections 147–151, introduced Section 148A, and reduced limitation periods ...
Income Tax : The Finance Bill, 2026 clarifies who can issue notices under sections 148 and 148A. It confirms that only jurisdictional Assessing...
Goods and Services Tax : The court held that once late fee is imposed for delayed annual return filing, a further general penalty is not permissible. Secti...
Income Tax : The issue was whether an assessment could be reopened after four years. The Court held that full disclosure by the taxpayer barred...
Income Tax : Learn about the new block assessment provisions for cases involving searches under section 132 and requisitions under section 132A...
Income Tax : Discover how Finance Act 2021 revamped assessment and reassessment procedures under Income-tax Act, impacting notices, time limits...
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 issue was deletion of additions on unsecured loans treated as unexplained cash credits. The tribunal upheld deletion, holding ...
Income Tax : The issue involved dismissal of appeal due to delay and non-appearance. The tribunal condoned the delay citing medical reasons and...
Income Tax : The issue was whether reassessment could be initiated after four years without fresh evidence. The court held such reopening inval...
Income Tax : The issue was whether reassessment notice issued without approval from the correct authority is valid. The tribunal held it invali...
Income Tax : The Court held that reassessment proceedings must be initiated within the statutory time limit. It found the notice issued after t...
Income Tax : ITAT Chandigarh held that ITO Ward-3(1), Chandigarh had no jurisdiction to issue notice to an NRI and hence consequently the asses...
Excise Duty : Notification No. 29/2024-Central Excise rescinds six 2022 excise notifications in the public interest, effective immediately. Deta...
Income Tax : Learn how to initiate proceedings under section 147 of the IT Act in e-Verification cases. Detailed instructions for Assessing Off...
Income Tax : Explore e-Verification Instruction No. 2 of 2024 from the Directorate of Income Tax (Systems). Detailed guidelines for AOs under I...
Income Tax : Supreme Court in the matter of Shri Ashish Agarwal, several representations were received asking for time-barring date of such cas...
Karnataka High Court set aside the ex-parte reassessment (u/s 147 and 144) because all preceding notices (including 148A) were mailed to taxpayer’s outdated address. HC found merit in bona fide non-receipt due to address change and remanded matter for fresh consideration.
The Karnataka High Court set aside the reassessment (u/s 147 and 148) because the jurisdictional AO issued notices, violating the Section 151A mandate for faceless reassessment. The ruling reinforces that all orders based on notices issued outside the scheme’s scope are void and stand quashed.
The Karnataka High Court set aside the reassessment proceedings, including Section 148A and consequential penalty orders, ruling they were initiated without jurisdiction. The court found that the jurisdictional AO issued notices outside the scope of Section 151A, violating the CBDT’s faceless scheme.
ITAT Chandigarh quashed an assessment order made under Section 143(3) for a pre-search year, holding that after a Section 132 search, the assessment must mandatorily proceed under Section 148 with proper Section 148B approval. The tribunal ruled that the Assessing Officer’s continuation of the scrutiny post-search was a jurisdictional error, making the assessment void ab initio.
The ITAT Ahmedabad sent back a case involving an addition of Rs.1.17 crore for unexplained cash deposits to the AO. The remand was necessary because the CIT(A) issued an ex-parte order without verifying the evidence submitted by the assessee.
The Karnataka High Court quashed the entire chain of faceless reassessment proceedings, including Section 148A, Section 147, and penalty orders. The ruling was based on the reason that the notices were issued by the jurisdictional AO outside the mandatory procedure of Section 151A (Faceless Assessment Scheme). The key takeaway is the non-compliance with the statutory mechanism for faceless proceedings invalidates the entire reassessment.
The Karnataka High Court ruled that reassessment under Section 153A is invalid when no incriminating material is found during a search. The Court held that conversion of a firm into a company, fulfilling Section 47(xiii) conditions, is not taxable as a transfer.
ITAT quashed a reassessment, ruling that S 148 notice was invalid because it was issued before AO formally received mandatory sanction from PCIT under S 151. Relying on Supreme Court, Tribunal held that internal approval is insufficient; communication of sanction to AO is a jurisdictional prerequisite.
Tribunal observed that AO accepted returned income without any independent examination or inquiry. As major issues like estimation of profit in liquor trade and tax audit requirements were ignored, assessment was held erroneous. Pr. CIT’s revision under Section 263 was sustained.
ITAT Delhi deleted a ₹31.35 lakh addition for alleged inflated purchases, ruling that an assessment cannot rest solely on third-party search data. The Tribunal emphasized that the Revenue failed to conduct any independent enquiry or provide corroborating evidence linking the assessee to the alleged cash transactions.
