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Corporate Law : Income Tax Gazetted Officers’ Association (W.B.) Unit Date: 02.02.2023. To The Principal Chief Commissioner of Income Tax, W...
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Red Chilli International Sales Vs ITO (Supreme Court of India) We with the petitioner that the impugned judgment rejecting the writ petition on the ground of alternative remedy does not take into consideration several judgments of this Court, on the jurisdiction of High Court, as writ petitions have been entertained to be examined whether the […]
Evaluate the reasonableness of Notices issued under section 148 of Income Tax Act, as amended in the Finance Act 2021. Get to know the time limits for issuing a Reassessment Notice.
ITAT Kolkata held that disclosure of undisclosed income under IDS, 2016 on which taxes are duly paid cannot be further added as undisclosed stock. Claim of set off of undisclosed income duly available against the undisclosed stock surrendered during the course of survey.
ITAT Chennai held that AO having chosen not to scrutinize the return cannot resort to the provisions of section 147 of the Income Tax Act in absence of any new or fresh material indicating escapement of income.
ITAT Kolkata held that addition cannot be made on protective basis in the reopened assessment proceeding as the assessment cannot be reopened for a contingent nature of addition.
Vodafone Mauritius Limited Vs ACIT (Delhi High Court) Ms Fereshte D. Sethna, who appears on behalf of the petitioner, says that the principal allegation against the petitioner is that the petitioner, which is a foreign company incorporated under the laws of Mauritius, had sold shares worth Rs.1295 crores, of an Indian company going by the […]
Kailash Kedia Vs ITO (Orissa High Court) Learned counsel for the Petitioners have also assailed both the notice under Section 148-A(1)(b) of the Act as well as the consequential order under Section 148-A(1)(d) on several grounds including the ground of limitation, not considering the objections filed, not providing a personal hearing, non-application of mind to […]
Admittedly, the issuance of notice and initiation of re-assessment proceeding are beyond six years and, prima facie, it is barred by limitation both under the old Act as well as under newly amended provision relating to Section 147 of the Act.
In present case approval has been granted by the ld. JCIT without verifying the reasons recorded by the AO for initiating the proceedings under section 147 of the Act which is contrary to the provisions of law.
AO could have taxed the accrued income or re-opened the assessment within four years. A mere incorrect claim based on full disclosures cannot be reassessed after four years by invoking sections 147 and 148 of the IT act.