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...
Assessee to satisfy the authority by submitting Crypto currency ledger to verify information as was submitted by him before AO in proceedings under Section 148A
Can the I-T department call for reassessment when the Income Tax Act, 1961 does not provide for it – Per Incuriam application of Article 142
S. Raheja Realty Pvt. Ltd. Vs Office of Income Tax Officer (Gujarat High Court) On perusal of the Explanation (1) of the Section 148, it is clear that that for the purpose of Section 148A, the information with the Assessing Officer which suggests that the income chargeable to tax has escaped assessment means any information […]
Touchstone Holdings Pvt. Ltd. Vs ITO (Delhi High Court) Delhi High Court allows reopening of AY 2013-14 (despite being beyond 6 years from 1st April 2021), basing on extension as per Taxation and Other Laws (Relaxation and Amendment of Certain Provisions) Act, 2020 (TOLA). The time limit for issuing notice under unamended Section 149 which […]
No notice whatsoever was issued to the legal representative/s of the assessee before undertaking the reassessment proceedings. Thus, the impugned re-assessment and the assessment order having been passed against the dead assessee, is invalid and the same cannot be sustained in the eyes of law.
The foundation of a reassessment proceeding is a valid notice and if this notice is held to be invalid the entire edifice sought to be raised on such foundation has to collapse.
Ekaksh Commerce Pvt Ltd Vs ITO (Calcutta High Court) By this writ petition, petitioner has challenged the impugned order dated 27th April, 2022 under Section 148A(d) of the Income Tax Act, 1961, relating to assessment year 2018-19 on the ground that the same being without jurisdiction and contrary to the provision of Section 149(1)(a) and […]
Vikas Gupta Vs Union of India (Allahabad High Court) Important recent update on landmark Allahabad high court ruling in cases of Vikas Gupta & others vs UOI order dated 08 Septmber 2022 on fatal impact of lack of Mandatory requirement of valid sec 151 approval on part of approving authority Held quashing notices u/s 148 […]
Shrikant Phulchand Bhakkad Vs JCIT (Bombay High Court) It was seen that the issue under consideration of the office had not been examined by the assessing officer while passing the assessment order. The transactions entered into by the assessee were non genuine and were carried out with a view to avoid paying tax. The assessee […]
Ernst And Young U.S. LLP Vs ACIT (Delhi High Court) Supreme Court and this Court have repeatedly held that when the original proceeding has been completed under Section 143(1), there is no need for fresh tangible material for reopening the assessment and the doctrine of change of opinion does not arise since under Section 143(1) […]
