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 ITAT Hyderabad in ITO Vs. SR Peddi Estates India Pvt. Ltd. confirmed the deletion of a ₹4.39 crore addition made during reassessment. The Tribunal ruled that bank credits
The Tribunal held that capital gains did not arise in the relevant year because the JDA explicitly stated possession was deemed given only upon handing over the landowners’ built-up share. This means Section 45(1) cannot be invoked until actual possession or consideration is received, overriding the AO’s reliance on stamp duty valuation.
ITAT Hyderabad upholds remand for ex-parte reassessment, allowing the assessee to challenge the Section 148 notice validity based on the mandatory faceless procedure violation in fresh proceedings.
ITAT Ahmedabad deletes Rs.11.27 lakh addition for penny stock investment, ruling the Revenue failed to prove the investment originated from the assessee’s own unexplained funds under Section 69B.
ITAT Pune sets aside NFAC’s ex-parte order, mandating fresh adjudication on S. 44AD applicability to commission income, citing violation of natural justice and lack of proper notice.
ITAT Hyderabad in Pitti Holdings Pvt. Ltd. vs ACIT quashes a reassessment for the Assessment Year 2018-19. The order holds that notices issued by the Jurisdictional AO (JAO) instead of the Faceless AO (FAO) after the Faceless Jurisdiction Scheme 2022 are void ab initio.
Visakhapatnam ITAT dismisses Revenue appeals, quashing protective additions on cotton mills. Protective assessment for A.Y. 2016-17 invalid as substantive addition was in A.Y. 2017-18.
The ITAT Hyderabad ruled that reassessment notices under Sections 148A(b) and 148 issued by the Jurisdictional Assessing Officer (JAO) after April 1, 2022, are invalid and void ab initio. This decision reinforces the mandatory nature of the Faceless Jurisdiction Scheme, 2022, quashing the entire reassessment for lack of proper authority.
The ITAT Visakhapatnam ruled that protective additions made in reassessment proceedings are invalid because they did not co-exist with a substantive addition for the same assessment year. The Tribunal held that a protective assessment cannot stand in isolation and cannot be based on mere suspicion to keep a hypothetical option open for the Revenue.
This decision strengthens the protection against time-barred reassessment, emphasizing that the extended limitation under Section 149(1)(b) applies only if the escaped income is factually above ₹50 lakh. The ITAT confirmed the reassessment was invalid as the AO’s final order confirmed the escaped income was much lower than the extended limit required for reopening
