Income Tax : ITAT Mumbai invalidates reassessment against Shah Rukh Khan for FY 2012-13, addressing foreign tax credit claims and procedural fl...
Income Tax : Learn about Income Tax Act Section 147 assessment proceedings: reasons for reopening, notice issuance, objections, assessment proc...
Income Tax : Budget 2025 revises block assessment rules for search cases, covering undisclosed income, assessment procedures, penalties, and ti...
Income Tax : Under Section 147 of the Income Tax Act, reassessment cannot be based on a mere change of opinion by the AO. Read more on this leg...
Income Tax : SC clarifies reassessment notices under TOLA and Finance Act 2021 in Union of India v. Rajeev Bansal. Learn how decision impacts t...
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 : ITAT Ahmedabad held that CIT(A) rightly restricted disallowance on account of unexplained bank deposit and withdrawal under sectio...
Income Tax : It was held that in the original assessment under Section 143(1), the issue related to the deed of purchase of land was not looked...
Income Tax : ITAT Mumbai held that notice under section 148 of the Income Tax Act issued after a period of six years is barred by limitation. A...
Income Tax : ITAT Surat condones a 162-day delay in appeal filing by a 77-year-old farmer, citing lack of legal guidance, and directs a fresh a...
Income Tax : ITAT Mumbai rules that share transactions backed by DEMAT statements cannot be treated as bogus income without concrete proof....
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...
Corporate Law : Income Tax Gazetted Officers’ Association (W.B.) Unit Date: 02.02.2023. To The Principal Chief Commissioner of Income Tax, W...
Delhi High Court quashed reopening notice as well as reassessment order & all consequential proceedings initiated in the name of deceased & also held, interalia, that the LR of deceased are not obliged to intimate death to Income tax deptt & get PAN cancelled & that reassessment order can be challenged in such cases in writ petition.
Sh. Chand Singh Vs DCIT (ITAT Delhi) n the present case it is an undisputed fact that there was a failure by the AO to comply with the mandatory requirement of disposing of the objections raised by the assessee to the reopening of assessment in terms of the law laid down by the Hon’ble Supreme […]
Ess Advertising (Mauritius) S.N.C. Et Compagnie Vs ACIT (Delhi High Court) No Power to Carry Out Reassessment On Same Material And Facts Available On Record And Rubber Stamp Approval Held Invalid Following Synfonia Decision Of Own Court Thus, the moot question, which arises for consideration, is: should the respondent be permitted to assess the petitioners‟ […]
Time limit to issue notice- One of the major differences between the new and old regime is the time limit of issue of notice, under the earlier regime the time limit for issue of notice was 4 years from the end of the relevant assessment year however in certain circumstances it was 6 and 16 years.
The Assessing Officer having arrived at his subjective satisfaction based on additional fresh material placed before him that the petitioner had not fully and truly disclosed all the material facts necessary for his assessment for the relevant assessment year and prima facie his income chargeable to tax had escaped assessment, he was fully justified in initiating the proceedings under section 147/148 of the said Act.
Court is not satisfied that the Petitioner has made out any case for interference by the Court at the present stage, i.e. the stage of issuance of the notice for reopening of the assessment under Section 147
Finance Act, 2021 made the existing procedure of reassessment under section 147 of the Income Tax Act (‘Act’) completely redundant by substituting it with a new reassessment procedure. Memorandum Explaining the Finance Bill, 2021 makes it amply clear that such changes are killing two birds with one stone viz. 1. Less Litigations and 2. Ease of Doing business for the taxpayers.
Re-opening of the assessment proceeding was conducted on the basis of legally valid sanction accorded by the authority under provisions of Section 151 and the same was justified as it had been initiated on the basis of the material which had given rise to reason to believe as well as escapement of assessment had been quantified by AO.
NEW REASSESSMENT PROCEDURE 1. Introduction: In the film JOLLY LLB, the judge, unforgettably played by actor Saurabh Shukla, in the concluding speech while delivering his judgment says: ‘But I am the judge. who knows what, what I feel, judgment cannot be given on that basis. I HAVE TO GIVE JUDGMENT ON THE BASIS OF EVIDENCE. […]
M/s. Kone Elevators (India) Pvt. Limited Vs ACIT (Madras High Court) Undoubtedly, the assessee had not submitted the ratification certificate to be obtained from the CBDT for claiming exemption under Section 10B of the Act. However, there are certain confusions even within the Department Officials regarding production of such ratification certificate from the CBDT. The […]
