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 case examined reassessment based on third-party information without independent application of mind. The Tribunal ruled that r...
Income Tax : The Tribunal relied on Supreme Court precedent to hold that interest on tax arrears is compensatory, not penal. It ruled that such...
Income Tax : The Tribunal held that absence of a clear charge in the penalty notice makes the proceedings invalid. It ruled that failure to spe...
Income Tax : The case examined validity of a reassessment notice issued beyond statutory limits. The ITAT held the notice invalid as it exceede...
Income Tax : The Tribunal upheld reopening under Section 147 as Form 26AS reflected substantial contract receipts despite no return being filed...
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...
Keenara Industries Private Limited Vs ITO (Gujarat High Court) In the case of Keenara Industries Private Limited Vs ITO and other 256 cases Gujarat High Court set aside Notices under section 148 of Income Tax Act, 1961 and impugned orders under section 148A(d) on the ground of limitation. FULL TEXT OF THE JUDGMENT/ORDER OF GUJARAT HIGH […]
Bombay High Court held that initiation of reassessment proceeding under section 148 of the Income Tax Act, in absence of any failure on the part of the assessee to disclose any material facts fully and truly during the regular assessment proceedings, is mere change of opinion and hence liable to be quashed.
Rajeev Bansal Vs Union of India (Allahabad High Court) Allahabad high court in lead case of Rajeev bansal vs UOI (Writ Tax of 1086/2022) and others by division bench presided by justice sunita agarwal on issue of time barred notices u/s 149 first proviso under amended law (judgment reserved on 15 Dec 2022) has rejected […]
Bombay High Court held that reopening of assessment under section 148 in absence of any new information received by AO between the date of assessment order u/s 143(3) till the issuance of notice u/s 148 is unjustified and untenable in law.
HC quashed section 148 notice issued without sufficient reasons to initiate reassessment proceedings without satisfying conditions precedent under Section 147
Bombay High Court held that reopening of assessment in absence of failure on the part of the assessee to disclose fully and truly the material facts and also in absence of any tangible material is unjustifiable.
Revenue Department could only re-open an assessment beyond four years, if there was a failure on the part of assessee to disclose material facts fully and truly and not on the basis of reason to believe without satisfying jurisdictional condition required under provisions of Section 147
Bombay High Court held that AO failed to satisfy the direction given by the court while issuing notice under section 148 of the Income Tax Act. Accordingly, order for reopening of assessment and demanding penalty u/s 271(1)(c) are quashed and set aside.
If foundational allegation is missing in notice issued under Section 148A(b), the same cannot be incorporated by issuing a supplementary notice.
Dr. Mathew Cherian Vs ACIT (Madras High Court) Facts of the Case: 1. There was a survey in Kovai Medical Centre and Hospital (in short KMCH or hospital) by the officials of the Income Tax Department, on 11.2021. In the course of the survey, various documents were found and seized that, according to the respondents, […]
