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...
Delhi High Court held that concluded and closed assessments cannot be reopened merely on suspicion. Accordingly, reopening of assessment is liable to be quashed since there is no tangible material that has a live nexus to reason to believe that the income has escaped assessment.
This paper aims to: 1.Compare the latest amendments introduced by the Finance (No.2) Act, 2024 with the law that existed previously; 2. Analyze the intent and rationale behind the legislative changes; 3. Discuss the practical scope and implications of the new provisions on reassessment proceedings.
Under section 151(ii), where the alleged escaped income was more than Rs. 50 lakh, and where more than three years have passed since the relevant assessment year require approval from a higher-level authority.
ITAT Delhi quashes reassessment for AY 2015-16, finding the Section 148 notice issued on July 29, 2022, was beyond the statutory limitation period.
Madras High Court held that period of limitation for issuing notice under section 153C of the Income Tax Act to person other than searched person shall be date of receiving books of accounts or documents seized by AO having jurisdiction over such other person.
Madras High Court held that reopening of assessment beyond the period of limitation prescribed under section 149(1)(a) and (b) of the Income Tax Act is without jurisdiction. Accordingly, writ petition is allowed and proceedings set aside.
ITAT Chennai held that reopening of assessment u/s. 148 of the Income Tax Act on mere change of opinion without satisfying necessary ingredients for initiating reassessment is invalid and liable to be quashed. Accordingly, reassessment set aside.
By returning the loan, the assessee has only utilised the loan for the purpose of business and repaid the same. Merely because some operator has managed the affairs and all the transactions cannot be labelled as non-genuine.
The Petitioner prayed for a direction upon the respondents not to proceed further on the basis of the notice u/s. 148 of the Act of 1961 and drop the proceedings after considering the objection dated 21.02.2022. Petitioner also prayed for an interim stay of the impugned notice.
Addition made under Section 69A based only on statements and a pen drive that were never tested or corroborated was not justified as such evidence could not be treated as credible unless the taxpayer was confronted with it and given an opportunity to respond.
