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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 ITAT Mumbai held that a reassessment notice issued beyond three years was invalid where the alleged escaped income was less than ₹50 lakh. The consequential assessment order was quashed.
The Amritsar ITAT held that reassessment proceedings were invalid where the officer completing the assessment had not issued the notice under Section 148. The reassessment order was quashed on jurisdictional grounds.
The Tribunal ruled that reassessment based on a different interpretation of the same material examined during the original assessment amounted to a change of opinion and could not justify reopening.
The Court held that the Assessing Officer could not refer the matter to the Valuation Officer under Section 55A where the assessees registered valuer had reported a higher value. The reassessment based on such reference was therefore held impermissible.
The Court held that while the assessees reply period had to be excluded under Section 149, the Assessing Officer still failed to issue the Section 148 notice within the extended statutory timeline. The reassessment notice was therefore quashed as time-barred.
The Rajasthan High Court held that reassessment proceedings against legal representatives of a deceased assessee must comply with Section 148A(b). Notices and orders issued without following the mandatory procedure were quashed.
The ITAT Mumbai held that purchases cannot be treated as entirely bogus merely based on Sales Tax Department information when the assessee produced invoices, bank statements, stock records, and delivery challans. The Tribunal directed that only the profit element embedded in the alleged non-genuine purchases, if any, should be taxed.
The Tribunal ruled that reassessment proceedings cannot survive when reasons recorded for reopening demonstrate non-application of mind. Following the Delhi High Court’s findings in the preceding year, the reassessment was declared invalid.
The Bangalore ITAT held that a Section 40A(3) disallowance cannot be made on the assumption that cash payments might have exceeded statutory limits. The Tribunal deleted the addition after finding that records showed payments were made through banking channels.
Mumbai ITAT ruled that where a capital asset was acquired before 01.04.2001, the claim for adopting fair market value as on that date must be examined on merits. The key takeaway is that statutory valuation rights cannot be rejected on technical grounds alone.