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...
Cognizant Technology Solutions India P. Ltd. Vs Asst.CIT (Madras High Court) Facts- Impugned notice was issued under section 148 for reopening of the assessment. The petitioner questioned the legal validity of the initiation of the reopening proceedings. Conclusion- If the Assessing Officer has reason to believe that the particular issue has not been considered or […]
Transway Wine Pvt. Ltd. Vs PCIT (Calcutta High Court) Impugned notice is quashed solely on the ground that the impugned notice was issued in the name of non-existing company in spite of revenue having notice and knowledge of non-existence of such Company. Quashing of this notice will not prevent the respondents from issuing fresh notice in […]
Saurabh Natvarlal Soparkar Vs ACIT (Ahmedabad High Court) it is evident that a specific query was raised by the Assessing Officer with respect to Section 14A and the same was appropriately replied by the writ applicant. The same was accepted at the relevant point of time. Once again the very same issue is sought to […]
Cognizant Technology Solutions India Private Limited Vs ACIT (Madras High Court) Conclusion: In present case, the Division Bench of the Hon’ble Madras High Court provided relief to the Petitioner observing that in the absence of new facts coming to the knowledge of the Assessing Officer subsequent to the original assessment proceedings, the reopening could not […]
Madan Mohan Tiwari Vs ITO (ITAT Delhi) Once information received by AO were shown in objections as incorrect, entire jurisdiction on such reasons cease to exist and thus reopening should be dropped. Such non application of mind therefore at recording reasons as well as disposal of objections invalidate entire reopening. FULL TEXT OF THE ORDER […]
The AO reopened the assessment of the Assessee after it was observed that the Assessee had not reflected or explained his investment in a hotel project during a survey operation. Thereafter, the Assessee filed an application before the CIT(A) challenging the validity of reopening of assessment, which was subsequently rejected and disposed of by the CIT(A) on the ground that the AO had correctly followed the procedure as contemplated in the IT Act and there was no infirmity in the action of the AO regarding reopening, all of which has been in accordance with law.
Hon’ble Tribunal uphold the observations of Ld. CIT(A) wherein it was observed that in order to assess the asset/bank account held by a third party in the hands of the respondent assessee the department has to prove that the assessee has direct beneficial interest in the asset/bank account held by third party.
JRS Pharma and Gujarat Microwax Private Limited Vs DCIT (Gujarat High Court) Question of law: whether the revenue is justified in reopening the assessment for the year under consideration? Writ application filed before the Hon’ble HC of Gujrat challenging notice u/s 148 of the Income Tax Act, 1961 for reopening the assessment for AY 2013-14. […]
Dove Consultants Pvt. Ltd. Vs DCIT (ITAT Delhi) Reopening Based on Information must be Reliable and Some Evidence to Believe Purchase as Bogus, Proceedings Quashed By Delhi ITAT We have considered the rival contentions of both the Ld. Representative of the parties. A perusal of the reasons recorded for reopening of the assessment (as reproduced […]
Ashok Kumar Agarwal Vs Union of India and 2 Others (Allahabad High Court) Ashok Kumar Agarwal (the Petitioner) had filed a Petition to challenge the initiation of re-assessment proceedings under Section 148 of the Income Tax Act, 1961 (the IT Act) for different Assessment Years (AYs). The Petitioners contended that all the impugned re-assessment proceedings had […]
