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...
In the case of ITO Vs. M/S JAGDAMBA OPTICS PVT. LTD. Delhi Bench of ITAT have held that there was existence of correct information which prompted to the AO to proceed to issue notice u/s. 148 of and hence, the reassessment proceedings could not be declared as null and void.
Delhi High Court held In the case of CIT vs. Vishishth Chay Vyapar Ltd. that the legal requirement that the reason to believe must be predicated on tangible material or information” and that the belief must be rational and bear a direct nexus to the material on which such a belief is based” was not fulfilled in the present case.
Delhi High Court held In the case of Shri Parasram Industries Pvt. Ltd. vs. ITO that the present case is related to change of opinion. This is so, because in the questionnaire, the AO specifically raised the issue with regard to the validity of shareholdings.
Raj Hans Towers Pvt. Ltd. -Vs- ITO (ITAT Delhi) There is no tangible material, which come to the possession of the AO to lead to the conclusion that there was an escapement of income from assessment.
The assessment under Section 143(3) was originally done on 19.12.2008. The notice under Section 148, which is impugned herein, has been issued beyond the period of four years from the end of the relevant assessment year.
In the case of Muller & Philpps (India) Ltd vs. ITO, Hon’ble ITAT Mumbai held that the position of law is clear. It has been held by Hon’ble Supreme Court in the case of GKN Driveshaft 259 ITR 19, that it is mandatory on the part of the AO to provide the copy of the reasons to the assessee
This was a case where the original assessment was completed under Section 143 (3). In other words there was a complete scrutiny of the accounts and all the affidavits of the donors furnished by the Assessee pursuant to the questionnaires issued to him by the AO. In the absence of any adverse
Krypton Industries Ltd. V/s. DCIT (ITAT Kolkata)- Whether the action of AO for framing the assessment under section 147 is within his jurisdiction though the time for scrutiny assessment under section 143(3) has not lapsed.
Mangi Lal Sethia Vs ITO (ITAT Kolkata) In this present case, we find no live link between the reason to believe and reopening of case u/s 147 of the Act. It was a loan entry in the books of the assessee and the same was also settled within the same year.
M/s.Peacock Apparels (P) Ltd vs. ITO (Madras High Court), Except to state that the EOU has not been approved by the Specific Authority, the first respondent has not assigned any other reason to reopen the assessment order.
