Income Tax : ITAT Mumbai held that an addition under Section 69A cannot be sustained when the assessee is denied the opportunity to cross-exami...
Income Tax : ITAT held that additions based solely on third-party search material without independent evidence or cross-examination are invalid...
Income Tax : ITAT held that a return filed under section 148 remains valid even if delayed. Failure to issue mandatory notice under section 143...
Income Tax : Judicial rulings clarify that satisfaction for initiating action against other persons in search cases must be recorded promptly. ...
Income Tax : The Finance Bill 2026 proposes allowing taxpayers to file an Updated Return even after receiving a reassessment notice under Secti...
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 : 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 : ITAT Indore held that appellate order violated principles of natural justice after finding that key hearing notices were sent to a...
Income Tax : Court ruled that reassessment notices under Section 148 must be issued through the faceless mechanism under Section 151A and the 2...
Income Tax : The Madras High Court held that reassessment notices required to be issued by the Faceless Assessing Officer are invalid if issued...
Income Tax : The Madras High Court held that reassessment notices required to be issued by the Faceless Assessing Officer are invalid if issued...
Income Tax : The Jharkhand High Court held that retrospective insertion of Section 147A removed the jurisdictional challenge against reassessme...
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 Court held that a Section 148 notice issued by the Jurisdictional Assessing Officer is invalid where the faceless system applies. It quashed the reassessment proceedings and confirmed that such notices must be issued only by the Faceless Assessing Officer.
The Tribunal held that a reassessment notice issued beyond three years was invalid because approval was taken from the PCIT instead of the PCCIT. The ruling reiterates that the 2023 amendment to Section 151 cannot be applied retrospectively.
The Court ruled that Section 148 notices issued by the local Assessing Officer, following orders under Section 148A(d), are legally valid. It rejected arguments that such notices must be issued facelessly under the 2022 Scheme. This establishes that notice issuance and faceless assessment are distinct processes.
ITAT Chennai ruled that notional contract values in F&O trading cannot be treated as real income. The case was sent back to the AO for reassessment based on actual profits and losses.
ITAT Chennai ruled that a delay in property registration due to the builder cannot deny a Section 54 deduction if the capital gains were reinvested on time. Timely payments, not registration, are the key requirement.
ITAT Chennai held that penalty under section 271(1)(c) of the Income Tax Act not sustainable since the additional income offered by the assessee was voluntary and addition is not based upon incriminating material seized during the course of search. Accordingly, order of CIT(A) upheld and appeal of revenue dismissed.
ITAT held that reopening of assessment under Section 148 is invalid if no fresh material emerges. Key takeaway: AO cannot reopen concluded assessments on pre-existing facts.
ITAT Chennai quashed a reassessment notice under Section 148, holding that an Assessing Officer cannot reopen an assessment based solely on a change of opinion without fresh tangible material. This safeguards taxpayers from arbitrary reassessments.
The Tribunal ruled that issuing a Section 143(2) notice before communicating reasons for reopening deprives the assessee of its statutory right to object. This violation invalidated the entire reassessment for the second year. The decision underscores that procedural fairness in reopening is a statutory mandate, not optional.
ITAT Delhi held that the addition of Rs. 73,99,475 as LTCG under Section 10(38) was unjustified, as the assessee provided complete evidence and no direct link to alleged bogus transactions was established.