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ITAT Mumbai quashes reopening beyond 3 years where escaped income is below ₹50 lakh, holding notice under Section 148 time-barred and invalid, thereby deleting consequential addition.
ITAT Mumbai rules redevelopment hardship compensation as capital receipt and deletes addition due to double taxation, granting relief where income was already taxed proportionately in later years.
ITAT Mumbai quashed reassessment as approval under Section 151 was obtained from the wrong authority. Notice under Section 148 held invalid, making entire proceedings void ab initio.
The court examined whether reassessment beyond six years was valid without identifying an asset. It held that the absence of any asset in recorded reasons makes extended limitation inapplicable. The key takeaway is that jurisdictional conditions must be strictly satisfied for reopening beyond six years.
The Tribunal dismissed the challenge to reassessment proceedings as no arguments were presented by the assessee. The ruling highlights that absence of pleadings can lead to automatic rejection of grounds.
The Tribunal invalidated reassessment proceedings since the Section 148 notice was issued after 01.04.2021, making it time-barred. The ruling reinforces strict limitation compliance for reopening cases.
The case examined reopening based on a prior disallowance under Section 80IB(10). The Court found that the disallowance had already been reversed by appellate authorities. Therefore, reopening based on the same ground was held invalid.
The Court held that reassessment cannot be initiated after expiry of the limitation period under the old regime. The notice issued after six years was declared invalid.
Orissa High Court held that assessment order set aside as proceedings under section 148 of the Income Tax Act initiated without serving of statutory notice. Accordingly, matter remitted back to AO to serve notice u/s. 148 as not hit by limitation u/s. 149.
ITAT confirmed validity of reassessment based on cash deposit information. However, it reduced addition by applying peak credit theory due to withdrawal patterns
