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...
ACIT Vs. K. S. Chawla & Sons (HUF) (ITAT Delhi) > HELD THAT:- In the present assessee’s case, search & seizure action u/s 132 of the Act was carried out on 15.10.2009 in the premises of Mr. Abhinav Arora and Mrs. Ranju Arora. Consequently, the Assessing Officer initiated reassessment proceedings u/s 147 of the Act […]
Sesa Sterlite Ltd. Vs ACIT (Bombay High Court at Goa) Section 147 : Reassessment-After the expiry of four years-Shah Commission’s report- Cash credit -Under-invoicing -Merely on basis of Shah Commission’s Report opining that there was under-invoicing of export price by iron-ore miners and exporters, reassessment could not be initiated when there was nothing to indicate […]
It is open to the Court to examine whether the reasons for the formation of the belief have a rational connection with or relevant bearing on the formation of the belief and are not extraneous or irrelevant for the purpose of the section.As explained by the Hon,ble Supreme Court of India in the following judgement […]
Analysis of sections 147, 148, 148A, 149 and 151 of the Income Tax Act, 1961 (Act) as substituted vide Finance Act, 2021 For the sake of convenience, pre-substituted sections and sections substituted Vide Finance Act, 2021 are tabulated as under: Pre-Substituted Sections Newly amended/substituted sections by Finance Act, 2021 Income escaping assessment. 147. If the […]
Merely saying that `loan had been advanced’ or `ITR had not been filed’, without disclosing the reasons, which led AO to hold such a belief , did not confer valid jurisdiction on the AO to take action u/s 147 and 148.
Understanding the differences between section 147 and section 143(2) proceedings. Learn about the nuances of these tax-related legal processes.
Reopening U/S 147 Not Valid If Certain Safeguards Not Followed By Revenue As Provided In section 147,148 And 151 of Income Tax Act, 1961 The important safeguards provided in sections 147,148 and 151 has not to be treated lightly by the concerned Assessing Officer and CIT as held in Chuggamal Rajpal Vs. S.P.Challia & others […]
Reassessment made by AO in respect of assessee-bank was quashed as no new material was brought on record by AO in the reopening of assessment to establish that the income of the assessee had escaped assessment as assessee had already disclosed all the information necessary for completion of original assessment and the reopening of assessment made beyond four years from the AY under consideration.
VSR Enterprises Vs ITO (ITAT Delhi) Assessing Officer in the instant case has recorded incorrect/wrong and non-existing reasons in the reason for reopening of the assessment and has not applied his mind to the information received from REIC, Ward 43(4)(New Delhi). Therefore, the reopening of the assessment is illegal and bad in law and is […]
Article on Reopening of Assessment Beyond Period of Four Years when Assessment Already Finalised Under Section 143(3) and All Material Facts Disclosed During Assessment Proceedings It is a trite law that when a statute provides a particular thing to be done in particular manner then the same has to be done in that manner only […]
