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Income Tax : Discover how Finance Act 2021 revamped assessment and reassessment procedures under Income-tax Act, impacting notices, time limits...
Income Tax : Humble Representation for modification of Section 151 of the Income Tax Act relating to Sanction for issue of Notice under sec. 14...
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 : Where unaccounted sales were established through seized material, only the net profit embedded therein was liable to tax, and not ...
Income Tax : ITAT Mumbai remanded the case to examine whether Section 56(2)(x) applied based on the agreement date and to consider refund of ex...
Income Tax : ITAT Bangalore remanded a Section 69A addition after holding that an APMC commission agent's entire sale proceeds could not be tre...
Income Tax : ITAT Kolkata condoned appeal delay, set aside the CIT(A)'s order, and remanded the assessment for fresh adjudication after grantin...
Income Tax : ITAT Mumbai quashed reassessment after finding no Section 143(2) notice and that the AO issued a final order disguised as a draft ...
Income Tax : The department has identified high-risk cases through its Insight Portal for AYs 2022-25. It directs officers to initiate reassess...
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...
Income Tax : Explore the latest guidelines for issuing notice under Section 148 of the Income Tax Act, 1961. Understand key procedures, amendme...
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...
ITAT Delhi quashed reassessment issued beyond three years where alleged escapement was only ₹35 lakh. Section 149 bars reopening unless the ₹50-lakh threshold is satisfied.
The Tribunal held that reassessment is invalid where the mandatory notice under Section 143(2) is issued beyond the prescribed time limit. Absence of a valid and timely notice strikes at the very jurisdiction of the Assessing Officer.
ITAT Delhi held that reassessment based on mechanical approval is invalid in law. Sanction must reflect independent application of mind by the approving authority.
The Tribunal ruled that the Assessing Officer could issue a reassessment notice only within the balance days available after excluding the stayed period. Issuance beyond that surviving window renders the notice time-barred.
The High Court held that a reassessment notice issued without a manual or digital signature violates Section 282A of the Income-tax Act. Such an unsigned notice is invalid in law, rendering all consequential proceedings unsustainable.
The assessment based on a second notice issued in July 2022 was quashed as time-barred. Once limitation had expired, subsequent notices could not revive reassessment jurisdiction.
The ITAT ruled that customer discounts are deductible when quantified and finalised in the year of claim, even if labelled as prior-period items. The decision reinforces that timing of crystallisation outweighs book classification.
The tribunal held that an ex parte assessment involving large unexplained bank credits required fresh adjudication. The matter was remanded to the Assessing Officer with one final opportunity to the assessee.
While recognising that earlier judgments had invalidated JAO-issued notices, the Court avoided passing orders that would make the pending appeal redundant. Instead, it directed the appellate authority to decide the matter expeditiously.
The court upheld the quashing of a reassessment notice where the reasons were based on vague portal information without a live nexus to income escapement. The ruling reiterates that reopening cannot rest on fishing or roving inquiries.
