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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 Court held that the approval granted for multiple search assessments was issued in a consolidated, mechanical form without case-specific consideration. It noted that Section 153D requires meaningful application of mind, which was absent in the approval examined by the Tribunal. The appeals were dismissed as no substantial question of law arose.
The Court ruled that reassessment proceedings initiated by a non-faceless officer violate the faceless regime. Both the Section 148 notice and the assessment order were quashed, subject to the Supreme Court’s final view on related precedents.
The Delhi High Court upheld that both Jurisdictional and Faceless Assessing Officers can issue reassessment notices under Section 148, dismissing claims of FAO-exclusive authority.
ITAT held that bank deposits consistent with declared fruit business turnover cannot be treated as unexplained under section 68; the addition of ₹1.29 crore was directed to be treated as genuine receipts.
ITAT held that framing reassessment without issuing a statutory 143(2) notice is invalid, quashing reassessments for a real estate company despite alleged bogus expenses.
Tribunal invalidated the reassessment because the Assessing Officer failed to obtain mandatory approval from the specified authority under Section 151(ii), rendering the Section 148 notice void.
The reassessment notice under Section 148 issued after 01.04.2021 did not comply with the amended provisions requiring enquiry and hearing. The NFAC held the reassessment order void ab initio. This ruling emphasizes strict adherence to procedural safeguards under amended law.
Tribunal holds that reassessment proceedings under Sections 147/148 are invalid as the notice was issued beyond the extended due date, following Supreme Court guidance in Rajeev Bansal.
The Tribunal held that reassessment proceedings initiated without a properly signed Section 151 approval are invalid. The notice under Section 148 was quashed, and the assessee’s appeal was allowed.
Tribunal deleted protective additions after finding no corresponding substantive assessment. The ruling clarifies that protective action cannot stand alone under Sections 147/143(3).