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 Chandigarh quashed an assessment order made under Section 143(3) for a pre-search year, holding that after a Section 132 search, the assessment must mandatorily proceed under Section 148 with proper Section 148B approval. The tribunal ruled that the Assessing Officer’s continuation of the scrutiny post-search was a jurisdictional error, making the assessment void ab initio.
Gujarat High Court held that non-filing of Income Tax Return as ignorant about deduction of TDS on account of land acquisition reasonable. Accordingly, delay condoned and petitioner allowed the file the income tax return of the relevant year.
The ITAT Ahmedabad sent back a case involving an addition of Rs.1.17 crore for unexplained cash deposits to the AO. The remand was necessary because the CIT(A) issued an ex-parte order without verifying the evidence submitted by the assessee.
The Karnataka High Court quashed the entire chain of faceless reassessment proceedings, including Section 148A, Section 147, and penalty orders. The ruling was based on the reason that the notices were issued by the jurisdictional AO outside the mandatory procedure of Section 151A (Faceless Assessment Scheme). The key takeaway is the non-compliance with the statutory mechanism for faceless proceedings invalidates the entire reassessment.
The Karnataka High Court ruled that reassessment under Section 153A is invalid when no incriminating material is found during a search. The Court held that conversion of a firm into a company, fulfilling Section 47(xiii) conditions, is not taxable as a transfer.
ITAT Chennai held that when sales are accepted and supported by records, entire purchases cannot be treated as bogus merely because suppliers were untraceable. Addition restricted to 12.5% as profit element.
ITAT quashed a reassessment, ruling that S 148 notice was invalid because it was issued before AO formally received mandatory sanction from PCIT under S 151. Relying on Supreme Court, Tribunal held that internal approval is insufficient; communication of sanction to AO is a jurisdictional prerequisite.
Tribunal observed that AO accepted returned income without any independent examination or inquiry. As major issues like estimation of profit in liquor trade and tax audit requirements were ignored, assessment was held erroneous. Pr. CIT’s revision under Section 263 was sustained.
The Andhra Pradesh High Court definitively ruled that Jurisdictional Assessing Officers (JAOs) lack the authority to issue reassessment notices (u/s 148A/148) after the Faceless Assessment Scheme (Section 151A) was notified in 2022. The court quashed the notices and orders, establishing that the faceless mechanism is the exclusive forum for initiating reassessment proceedings.
ITAT Delhi deleted a ₹31.35 lakh addition for alleged inflated purchases, ruling that an assessment cannot rest solely on third-party search data. The Tribunal emphasized that the Revenue failed to conduct any independent enquiry or provide corroborating evidence linking the assessee to the alleged cash transactions.
