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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...
The Assessing Officer proceeded with reassessment after three years based solely on PCIT approval. The Tribunal emphasized that compliance with Section 151 is mandatory, and failure renders the notice under Section 148 void.
Reassessment was quashed as the statutory process under the faceless regime was not followed end-to-end by the same authority. Such jurisdictional inconsistency vitiates the entire proceedings.
The Tribunal held that reassessment initiated solely on a Revenue audit objection, without fresh tangible material, is invalid. Reopening beyond four years on the same facts examined earlier amounts to impermissible change of opinion.
The ITAT Chennai held a reassessment notice under section 148 invalid as it was issued after the statutory limitation expired, emphasizing strict compliance with time limits.
The Tribunal held that reassessment under section 147 fails when seized search material exists. The correct and exclusive route is section 153C, making the reopening jurisdictionally invalid.
The Tribunal ruled that taxing entire bank cash deposits under section 69A without examining business explanations is unsustainable. The reassessment was restored for de-novo adjudication with conditions.
The Court reaffirmed that both JAO and FAO can validly initiate reassessment proceedings, notwithstanding contrary High Court views elsewhere.
The Tribunal held that reassessment initiated after three years was void because approval was taken from an incompetent authority. The key takeaway is strict compliance with section 151(ii) is mandatory and jurisdictional.
The ITAT ruled that long-term capital gains cannot be treated as bogus solely on suspicion when transactions are supported by proper banking, demat, and broker records.
The assessee neither filed returns nor responded to statutory notices, yet additions were deleted on appeal. ITAT held that absence of verification of source and compliance makes such deletion unsustainable.
