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 Jaipur quashed the reassessment order against Late Shri Jitendra Nagar, ruling the AO used the wrong authority (PCIT) for sanction under Section 151(ii), following the Supreme Court’s Rajeev Bansal precedent.
The ITAT Mumbai ruled that the power to reopen an assessment under Section 147/148 is invalid when a valid return is on record and the Assessing Officer still has time to initiate regular scrutiny under Section 143(2).
Relying on the jurisdictional High Court precedent, the Tribunal quashed the entire crore addition, holding that service of the notice beyond the statutory limitation date is a fatal flaw. The decision emphasizes that procedural compliance with the time limit is mandatory and cannot be waived.
The ITAT set aside the entire reassessment, holding that a valid notice is a mandatory jurisdictional step, citing the Supreme Court’s Hotel Blue Moon ruling. Since the two notices issued were defective (one premature, the other beyond the statutory time limit), the assessment was deemed illegal.
The issue was a ad-hoc addition on cash deposits sustained by the due to the absence of direct source-to-deposit correlation. The ITAT deleted the addition, holding that once the overall source (like agricultural or business income) is accepted on merits, does not require mathematical one-to-one matching.
The ITAT quashed the reassessment order as void because the final assessment was completed by an Income Tax Officer (Ward-2) who lacked jurisdiction, while the proceedings were initiated by another officer (Ward-3). The Tribunal, citing the Allahabad High Court, ruled that jurisdiction cannot be waived or conferred by participation.
Gujarat High Court held that reassessment under section 148 of the Income Tax Act is liable to be quashed since income earned in NRE Account is exempt under section 10(4)(ii) of the Act and hence there is no question of escapement of income.
he ITAT restricted a S.69A addition on ₹1 crore cash deposits, ruling that treating the entire gross receipt as unexplained income was unjustified for a commission agent. Considering the low-margin onion trading business and past assessments, the Tribunal estimated 4% of the deposits as the correct taxable commission income.
The ITAT Chennai upheld the quashing of a reassessment for AY 2017-18, ruling the u/s 148 notice invalid. As more than three years had elapsed, u/s 151(ii) required sanction from the Principal Chief Commissioner (Pr.CCIT), not the Principal Commissioner (Pr.CIT), confirming the jurisdictional defect.
The ITAT Ahmedabad, applying the Supreme Court’s Rajeev Bansal ruling and Gujarat High Court’s precedent, invalidated a reassessment for AY 2017-18. The order u/s 148A(d) and fresh u/s 148 notice, stemming from a deemed notice issued on 30.06.2021, were held time-barred as they were issued 20 days beyond the maximum seven-day ‘surviving time’ limit.
