Income Tax : Explore the legality of issuing a second notice under Section 148 of the Income Tax Act, 1961 for the same assessment year. Unders...
Income Tax : Explore the latest changes in Income Tax laws, including extinguishment of demands, return processing, form amendments, exemptions...
Income Tax : Delve into the provisions of Income Tax Act Sections 153A & 153C, governing assessments after search or requisition. Learn from co...
Income Tax : Explore recent Supreme Court rulings (2023) on income tax issues. Highlights of key cases, analysis, and implications....
Income Tax : Learn about Section 147 to 153 Income Escaping Assessment and Reopening of Cases Under Income Tax Act, 1961. Get guidance on the p...
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 : Under the provisions of Income-tax Act, 1961, notices for assessment/reassessment of income of old cases of more than six years fr...
Income Tax : One of the key sources of dispute is the existing arrangement for follow up on audit objections by Internal Audit Party and the Re...
Income Tax : Gujarat High Court quashes Income Tax reassessment notice against Deepak Natvarlal Pankhiyani HUF, citing lack of fresh evidence s...
Income Tax : PCIT Vs Farmson Pharmaceuticals Gujarat Pvt Ltd (Gujarat High Court): Reassessment cannot be solely based on a reevaluation of exi...
Income Tax : Assessee was engaged in diamond manufacturing, trading, and windmill power generation, had claimed deductions under sections 35DD ...
Income Tax : ITAT Raipur order on Rajesh Kumar Tiwari vs ITO. ITAT sets aside Income Tax reassessment completed without providing fair & reason...
Income Tax : Read the detailed analysis of Karrm Infrastructure Pvt. Ltd. vs. CIT at ITAT Mumbai. Learn why ITAT ruled that non-filing of GST b...
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...
Corporate Law : Income Tax Gazetted Officers’ Association (W.B.) Unit Date: 02.02.2023. To The Principal Chief Commissioner of Income Tax, W...
Income Tax : CBDT directed that cases reopened u/s 147/148A in consonance with Judgement of SC in case of UoI vs. Ashish Agarwal & CBDT instruc...
SBS Realtors Private Limited Vs ITO (ITAT Delhi) Learned Counsel for the Assessee submitted that since the re-assessment order is illegal and bad in Law and is covered by the Order of the Tribunal Dated 01.04.2019 in the case of assessee on the same issue, therefore, the Learned Pr. CIT cannot exercise jurisdiction under section […]
Important Judgement regarding reopening of assessment u/s 147 of the Income Tax Act, 1961 and redeposit of the same cash withdrawn from the bank earlier in sample written Submission before the Hon’ble CIT (A), Faceless
Red Hat India Pvt. Ltd. Vs DCIT (ITAT Mumbai) From the bare reading of the proviso to section 147 of the Act, it is mandatory on the part of the ld AO to duly mention in the reasons recorded itself as to whether there is any failure on the part of the assessee in disclosing […]
Synfonia Tradelinks Pvt Ltd Vs ITO (Delhi High Court) 1. The reasons which lead to the formation of opinion or belief that the assessee’s income chargeable to tax has escaped assessment should be inextricably connected. In other words, the reasons for the formation of opinion should have a rational connection with the formation of the […]
It is hereby- directed that the information received from Central Charges after 01.04.2019 may be considered as ‘Potential cases’, if ii has not been uploaded into VRU/CRIU functionality and is so flagged to the Jurisdictional Authorities concerned by the Central In such cases. Para 1(v) of Board’s letter dated 04.03.2021 shall apply.
These non-PAN cases have been pushed by Systems to respective Pr. CCIT/Pr. CIT based on address. Considering the time involved in allotting PAN in such non-PAN cases and other technical issues involved in generating notices through the system, the following instructions are being issued for handling of such non-PAN cases:
Synfonia Tradelinks Pvt Ltd Vs ITO (Delhi High Court) Delhi HC explains certain well-established principles enunciated by the courts over the years vis-à-vis initiation of proceedings under Section 147 of the Act. (i) The reasons which lead to the formation of opinion or belief that the assessee’s income chargeable to tax has escaped assessment should […]
Garg Zevar Palace Pvt. Ltd Vs ITO (ITAT Delhi) Section 147 mandates that the case can only be reopened after expiry of four years only if there was a failure on the part of the assessee to fully and truly disclose all material facts necessary. The assessee has disclosed the fact of receipt of Rs.60,00,000/- […]
Balbir Investment Pvt. Ltd. Vs ITO (ITAT Delhi) A perusal of the reasons recorded by the Assessing Officer shows that he has reopened the assessment by recording the reasons that shares of G.J. Holdings has been procured by Blabir Investments Pvt. The relevant observations of the Assessing Officer in the reasons recorded by the Assessing […]
NXP India Private Limited Vs ACIT (ITAT Bangalore) In this case AO passed a combined order giving effect to earlier orders of Tribunal with regard to original assessment and also reassessment order u/s. 143(3) r.w.s. 147 of the Act which is incorrect. The AO must have passed distinct and separate orders giving effect to the […]
