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Mumbai ITAT has quashed reopening of assessment under section 147 made by AO only on the basis of information received from report of investigation wing.
Notice under Section 148 of the Act pertaining to the Assessment Year (AY) 2013-14 was issued on 30th March 2021, i.e., prior to 1st April 2021. Also, it was beyond the period of six years after the expiry of the AY in question
Calcutta High Court held that Income Tax authorities can initiate afresh proceedings if the previous proceeding were invalid as per law.
Stalco Consultancy & Systems Private Limited Vs PCIT (Orissa High Court) HC relied on the Supreme Court judgment in Union of India v. Ashish Agarwal and quashed notices under Section 148 of the Act which were issued prior to 1st April, 2021 but beyond the period of six years after the expiry of the relevant […]
Hede Ferrominas Pvt. Ltd Vs ACIT (Bombay High Court) Firstly, the Petitioner did not bother to file any returns during Assessment Year 2015-16. Secondly, the Petitioner did not bother to file any response to the notice dated 27.03.2021 seeking to reopen the assessment within the time limit allowed to the Petitioner. The Petitioner filed returns […]
SC held that it was not permissible to initiate proceedings under Section 147/148 pending proceedings under Section 154
ITAT Mumbai held that reopening of assessment alleging that assessee has failed to provide fully and truly all material facts necessary for his assessment is bad in law as details already made available to AO during the course of scrutiny assessment proceedings.
Neeraj Kumar Vs ITO (ITAT Delhi) From the penalty order, we observe that the Assessing Officer nowhere stated that the notices issued u/s 142(1) of the Act were served on the assessee. In the entire penalty order we observe that the notices said to have been issued by the AO but it is not the […]
A scheme has been formulated whereunder issuance of notice under Section 148 of the IT Act has to be through automated allocation and in a faceless manner, whereas in the instant case, the aforesaid procedure has not been followed, rather the notice has been issued by a particular person and not in a face less manner.
Kerala High Court held that before proceeding to issuance of notice u/s 148 of the Income Tax Act, the procedure contemplated u/s 148A needs to be complied. Matter remanded as opportunity for personal hearing not afforded before issuance of order.
