Income Tax : Smt. Ranjana Kumari/Kalta Vs DCIT/ACIT (Central) (ITAT Chandigarh) The appeals involved three assessees belonging to the Kalta Gro...
Income Tax : Learn the updated provisions governing rectification, assessments, reassessments, and appeals under the Income-tax Act. This guide...
Income Tax : The article explains how the Finance Acts, 2025 and 2026 have reshaped the Updated Return regime under Section 139(8A). It highlig...
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...
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 : 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...
ITAT Kolkata held that reassessment proceedings were invalid as the notice under Section 148 failed to disclose mandatory approval under Section 151. The Tribunal found the reopening to be mechanical and without independent application of mind, rendering the reassessment void ab initio.
The ITAT Delhi quashed reassessment orders for three assessment years (AY 2011-12, 2015-16, 2016-17) based on fundamental legal flaws. The ruling confirms that reassessments are invalid if initiated on wrong or substituted reasons, if they are time-barred (following the Supreme Court’s concession in the Rajeev Bansal case), or if they proceed without valid statutory sanction from the competent authority.
The Tribunal annulled a reassessment after finding the AO wrongly assumed no return was filed. It held that a notice under Section 148 issued without applying mind is invalid, reinforcing that “reason to believe” must rest on verified facts.
The ITAT Delhi upheld the deletion of a Rs.1.83 crore addition for alleged bogus loans, ruling that uncorroborated WhatsApp chats and retracted search statements cannot override documentary evidence. The Tribunal affirmed the loans were genuine, noting the assessee provided full proof of identity, creditworthiness, and genuineness via audited accounts, bank statements, and TDS on interest paid to the NBFC lenders.
ITAT Kolkata quashed the reopening assessment for AY 2015-16, ruling the Section 148 notice issued on 31.07.2022 was time-barred. This decision strictly follows the Rajeev Bansal (SC) judgment, which held that the TOLA extension for reopening notices did not apply to AY 2015-16 beyond 31.03.2021.
ITAT Kolkata quashed the reassessment for two assessment years, ruling it was invalid as the reopening occurred beyond the four-year limit from the original scrutiny assessment without any allegation of the taxpayer failing to disclose material facts. This aligns with the Supreme Court’s mandate under the first proviso to Section 147.
The ITAT Delhi confirmed the addition of Rs.25.35 lakh as unexplained investment for a house purchase under Section 69, ruling that the assessee failed to discharge the initial onus to prove the creditworthiness and genuineness of loans allegedly received from his mother and sister. The lenders lacked sufficient bank balances, and documentation was incomplete.
The ITAT Jaipur ruled that an entire reassessment order must be quashed if the Assessing Officer (AO) makes no addition on the specific issue for which the case was reopened. Following the binding Rajasthan High Court precedent in Shri Ram Singh, the Tribunal held that the AO loses jurisdiction to assess unrelated, other escaped income (like LTCG) once the initial reason to believe is found to be incorrect.
ITAT Mumbai held that reassessment orders issued outside the Faceless Scheme and without a valid DIN were void ab initio, striking down additions under Sections 69A/69B.
Mumbai ITAT deleted a ₹4.20 lakh addition, quashing the reassessment because the addition was based solely on uncorroborated, retracted search statements and “dumb documents.” The tribunal ruled that once retracted, statements lose evidentiary value without independent verification.
