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...
As held by Allahabad High Court in Mon Mohan Kohli Vs. Assistant Commissioner of Income Tax, it is concluded that law prevailing on the date of issuance of notice under section 148 has to be applied.
Rajdeep Marketing Private Limited Vs Income Tax Officer (Bombay High Court) HC observed that, If on identical reasons raised for Assessment Year 2012-13 petitioner’s explanation has been accepted and no addition made, certainly on the same ground, we wonder how an allegation of escapement of income can be made for the subsequent Assessment Years. In […]
Rationalization of provisions relating to assessment and reassessment The Finance Act, 2021 amended the procedure for assessment or reassessment of income in the Act with effect from the 1st April, 2021. The said amendment modified, inter alia, sections 147, section 148, section 149 and also introduced a new section 148A in the Act. In cases […]
Parinee Realty Pvt. Ltd. Vs ACIT (Bombay High Court) According to the JAO, survey report submitted by DDIT investigation indicate that interest should be charged at 12% per annum on loan given to sister concern totaling to Rs.4,17,04,380/- and therefore income chargeable to tax has been under assessed by the said amount. According to the […]
Introduction: – The Division Bench of Hon. Rajasthan High Court consisting of Chief Justice Akil kureshi and Justice Sameer Jain. in Sudesh Taneja vs. ITO DB W.P No.969/2022. Order dated 27.01.22 quashed the reassessment notices issued after 31.03.21. Earlier the Ld. Single judge of Hon. Rajasthan HC had quashed reassessment notices u/s 148 of the […]
Sudesh Taneja Vs ITO (Rajasthan High Court) In the writ petitions the petitioners have challenged respective notices issued by the Assessing Officers under Section 148 of the Income Tax Act, 1961 (‘the Act’ for short) for reopening assessments for various assessment years. All these notices have been issued after 01.04.2021 and pertain to relevant period […]
Giraben Atulbhai Shah Vs ACIT (Gujarat High Court) The objections raised by the assessee came to be disposed of by the Assessing Officer vide his order dated 16th November 2021 stating that the assessee sold immovable property for an aggregate value of Rs.52 Lakh and the same was not offered for tax in the return […]
Rashmi Motors Vs PCIT (Orissa High Court) 1. This matter is taken up by video conferencing mode. 2. It appears that a Division Bench of Allahabad High Court has in its judgment dated 30th September, 2021 in Writ Tax No.524 of 2021 (Ashok Kumar Agarwal v. Union of India) accepted the pleas challenging reassessment notice […]
Orissa HC quashes notice under Section 148 of IT Act, citing lack of approval and time bar. Full text of judgment included.
Court has held that beyond a period of 4 years, retrospective amendment u/s 115JB of the Act could not be a ground for reassessment. Such legal proposition requires no authority of law.