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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 Tribunal ruled that the Revenue must establish a direct connection between seized material and the assessee’s taxable income before invoking Section 153C. Mechanical initiation of proceedings for multiple years was declared invalid.
The Tribunal held that validity of reopening under Section 148 must be tested on the basis of material available when reassessment proceedings are initiated. Subsequent reduction in additions does not invalidate jurisdiction already assumed.
Hyderabad ITAT held that a notice issued under Section 148 after six years from the end of AY 2015-16 was invalid. The Tribunal ruled that the amended 10-year reopening provision cannot revive already time-barred cases.
Chennai ITAT held that reassessment notices issued after three years must comply strictly with Section 151(ii) approval requirements. Failure to obtain sanction from the proper authority vitiated the entire reassessment proceedings.
The ITAT Ahmedabad held that reassessment under Section 147 was invalid because the Assessing Officer reopened the case for fictitious loan entries but made additions for alleged bogus LTCG from penny stock transactions. The Tribunal ruled that changing the basis of reopening is not permissible in law.
The Delhi High Court held that material recovered during a search can validly form the basis of reassessment proceedings even if the search is later alleged to be illegal. The Court ruled that proceedings initiated on the basis of such material do not automatically become void.
The Kerala High Court held that delay condonation applications under Section 119(2)(b) must comply with the revised five-year limitation prescribed by CBDT circulars. The Court ruled that authorities cannot entertain applications filed beyond the revised period.
The Tribunal ruled that an assessee following mercantile accounting must offer interest income to tax on accrual basis, irrespective of delayed receipt. Failure to disclose the full accrued amount in the relevant year justified reassessment and addition.
ITAT Mumbai held that additions under section 68 cannot survive where the Assessing Officer failed to conduct independent verification of alleged accommodation entries. Reliance solely on third-party investigation reports was rejected.
ITAT Ahmedabad held that reassessment under Section 147 was invalid as the Assessing Officer failed to show independent application of mind or establish a nexus between investigation material and escaped income.