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...
ITAT Mumbai held that reopening of assessment under section 147 of the Income Tax Act impermissible since based solely on change of opinion without any new tangible material. Further, even on merits royalty payment represents a legitimate business expenditure allowable u/s. 37(1).
Gujarat High Court held that assessment order passed under section 147 of the Income Tax Act without granting opportunity of personal hearing is not tenable. Accordingly, the order is quashed and appeal is allowed.
The ITAT Delhi deleted additions made under Section 153A for unabated/completed assessment years (AYs 2013-14 to 2016-17) following a search. The ruling strictly applied the Supreme Court’s mandate in Abhisar Buildwell that additions in completed years require the finding of incriminating material during the search.
The ITAT Rajkot set aside the addition of ₹16.99 lakhs in Long Term Capital Gain (LTCG) against the assessee, who acted only as a Power of Attorney (POA) holder for the property sale. The Tribunal remitted the matter to the Assessing Officer for fresh adjudication, noting the assessee was not the property owner or seller.
Additions of unsecured loans were sustained where creditworthiness was not proved, and relief upheld only for creditors who responded to notices under section 133(6) or furnished adequate documentation. Assessee’s case was reopened under section 148, where AO noticed unsecured loans aggregating to ₹14.94 crore from 164 creditors. On verification.
Karnataka High Court held that issuance of reassessment notice under section 148 of the Income Tax Act after expiry of statutory period of limitation as prescribed under section 149 of the Income Tax Act is liable to be quashed. Accordingly, petition allowed.
The Delhi High Court set aside the second Section 148 notice, ruling it was time-barred and constituted an illegal initiation of parallel reassessment proceedings.
The ITAT Delhi upheld the deletion of an addition for alleged penny stock LTCG under Section 68, ruling that an assessment for an unabated year under Section 153A requires incriminating material found during the search. Since the addition was based on general analysis, not seized documents, the Revenues appeal was dismissed. The key takeaway affirms the Supreme Courts mandate that completed assessments cannot be disturbed without specific incriminating evidence.
The ITAT Ahmedabad deleted a Rs.1.02 crore addition made under Section 68, rejecting the AO’s claim that a loan was an accommodation entry. The Tribunal ruled the loan was a genuine business transaction, used specifically for repaying an existing business loan, establishing the required nexus and purpose.
ITAT Delhi directed the AO to compute Annual Letting Value (ALV) only for the portion of the house property actually rented out (third/fourth floors). Taxing the entire property based on assumptions, ignoring the owner’s self-occupation, was held to be unjustified.
