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...
The Tribunal held that failure to provide opportunity to cross-examine foreign information sources amounted to violation of natural justice. Additions based on unverified documents were therefore invalid.
The Tribunal clarified that even where the assessee owns more than ten trucks, Section 44AE can be used as a fair yardstick for income estimation. Arbitrary assessment and multiple additions were set aside.
The Tribunal ruled that incorrect computation of opening and closing stock during survey cannot justify full addition. Only the reconciled excess stock amount already offered to tax was sustained.
Citing judicial precedents, the Tribunal held that failure to provide underlying material before passing order under Section 148A(d) invalidates reopening. The assessment order was consequently quashed.
Holding that the Assessing Officer recorded a mechanical satisfaction note without concrete incriminating evidence, the Tribunal dismissed the Revenues appeals and confirmed invalid jurisdiction under Section 153C.
The Tribunal emphasized that approval from the correct specified authority is mandatory where reopening exceeds three years. Failure to comply rendered the reassessment proceedings void ab initio.
The Tribunal held that reassessment beyond four years is invalid where the assessee had fully disclosed material facts during original scrutiny. In absence of failure to disclose, reopening under Section 147 was quashed.
The ITAT held that approval under Section 151 was invalid as the PCIT merely noted As per Annexure without independent satisfaction. The reassessment under Section 147 was declared void ab initio.
The Tribunal held that reassessment proceedings fail when the Assessing Officer abandons the issue forming the basis of reopening. In such cases, other additions cannot be made without issuing a fresh notice under Section 148.
Bombay High Court held that notice u/s. 148 of the Income Tax Act issued after obtaining sanction under section 151 from the non-competent authority is invalid and not sustainable in law. Accordingly, notice is liable to be quashed and petition is allowed.
