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Income Tax : The Supreme Court has remitted reassessment cases for fresh consideration after the retrospective insertion of Section 147A, leavi...
Income Tax : This article explains why reassessment proceedings may be invalid if the Assessing Officer merely relies on Investigation Wing rep...
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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 : 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 Tribunal ruled that once the assessee responds to a 148A(b) notice, the AO must complete the 148A(d)–148 cycle within the remaining time. In this case, the notice overshot the surviving limitation period, making reassessment legally defective. Consequently, all additions related to alleged accommodation entries and loans were quashed.
Tribunal quashed reopening under Section 147 where AO’s presumption of non-filing contradicted the documented return, citing Deepak Wadhwa precedent.
The Tribunal held that reassessment under Sections 147/143(3) is invalid without a Section 143(2) notice. It ruled that using the return filed under Section 148 triggers the mandatory requirement.
Delhi HC ruled that both jurisdictional and faceless officers can issue Section 148 notices. It reaffirmed that faceless regime does not eliminate JAO authority until Supreme Court decides otherwise.
Assessee succeeded in cross-objection as reassessment lacked jurisdiction and Section 69C addition was inapplicable, confirming deletion of addition and quashing proceedings.
Tribunal held that assessment was void because no notice under Section 143(2) was issued, confirming that such omission cannot be cured and invalidates entire assessment.
ITAT Bangalore set aside reassessment orders for AY 2015-16 to 2017-18, ruling that failure to issue mandatory notice under section 143(2) of the Income Tax Act invalidates the proceedings.
ITAT quashed reassessment notice issued by Jurisdictional AO instead of Faceless AO. Addition of ₹29.69 crore was invalidated, and Revenue’s appeal became infructuous.
The Bombay High Court held that a reassessment notice issued under Section 148 on 5th April 2022 is barred by limitation, following the Supreme Court’s Rajeev Bansal decision and prior High Court rulings.
The Gujarat High Court held that a notice issued under Section 148A(b) was procedurally flawed as it functioned as a Section 148A(a) inquiry. The notice, order under Section 148A(d), and subsequent notice under Section 148 were quashed.