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...
JRS Pharma and Gujarat Microwax Private Limited Vs DCIT (Gujarat High Court) Question of law: whether the revenue is justified in reopening the assessment for the year under consideration? Writ application filed before the Hon’ble HC of Gujrat challenging notice u/s 148 of the Income Tax Act, 1961 for reopening the assessment for AY 2013-14. […]
Dove Consultants Pvt. Ltd. Vs DCIT (ITAT Delhi) Reopening Based on Information must be Reliable and Some Evidence to Believe Purchase as Bogus, Proceedings Quashed By Delhi ITAT We have considered the rival contentions of both the Ld. Representative of the parties. A perusal of the reasons recorded for reopening of the assessment (as reproduced […]
Ashok Kumar Agarwal Vs Union of India and 2 Others (Allahabad High Court) Ashok Kumar Agarwal (the Petitioner) had filed a Petition to challenge the initiation of re-assessment proceedings under Section 148 of the Income Tax Act, 1961 (the IT Act) for different Assessment Years (AYs). The Petitioners contended that all the impugned re-assessment proceedings had […]
CIT Vs John Ettimootil Samuel (Madras High Court) The Tribunal, in our view, rightly took note of the fact that the reopening of the assessment was after four years and there was no tangible material to establish that the assessee failed to disclose fully and truly all materials, which are required for the assessment at […]
Green Park Estate Pvt. Ltd. Vs ACIT (ITAT Delhi) A perusal of the reasons recorded in the case of the assessee as well as in the case of M/s Green Valley Tower Ltd. are identical on the issue of alleged interest paid on post dated cheuqes. We have also gone through the paper book containing […]
On the basis of incriminating material found, once reassessment proceedings was initiated on the basis of incriminating material found in the search of 3rd party then the provisions of section 153C of the I.T. Act were applicable which exclude the application of section 147 and 148 of the I.T. Act and notice u/s. 148 of the Act and proceeding u/s. 147 are illegal and void ab initio
Indus Teqsite Private Ltd. (presently known as Data Patterns India Pvt. Vs DCIT (Madras High Court) Merely because the ratification has not been done by a Higher Authority, will it automatically vitiate the approval, which was granted by the Competent Authority namely the Development Commissioner. The learned Single Judge, after noting that the said assessee […]
Bansiwala Iron & Steel Rolling Mills Vs DCIT (ITAT Jaipur) Since the A.O. is a quasi-judicial authority, who has to collect the evidences, material and then to adjudicate the matter after due and complete application of mind. The A.O. expected to record his own satisfaction before reaching to any conclusion. In our view, the A.O. […]
Magma HDI General Insurance Co. Ltd. Vs. ITO (Calcutta High Court) Mr. Dutta could not satisfy this Court about what new material of documents came into the possession of the Assessing Officer after the order of assessment under Section 143(3) of the Act, which were not produced by the assessee before the Assessing Officer in […]
Ashok Kumar Agrawal Vs Union of India (Chhattisgarh High Court) It is submitted that on the date i.e. on 28.06.2021 when the notice under Section 148 of the Income Tax Act is issued, the power to issue the notice was preceded with a new provision of law and thereby Section 148 is to read with […]
