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...
Dr. Sajan Hedge Vs ACIT (Madras High Court) Conclusion: Instead of quashing the entire reassessment proceedings, it was suffice if an opportunity was provided to assessee to submit additional objections, if any, based on the materials relied on by assessee to AO, within a stipulated period and on receipt of the same, AO should be […]
Compare a situation where there is a pair of same-twin, one of whom is your employee. For some purposes, whether the sibling brother of your employee can replace your employee just because he is same-looking? The reason for the title because the Finance Act, 2021 has substituted section 148 with effect from 1-Apr-2021 and a […]
The deferment of application of old provisions of section 148 was done by the CBDT, Ministry of Finance by way of conditional legislation in the peculiar circumstances which arose during the pandemic and lock down. Hence, there being no full delegation of powers in the scenario, the Central Government cannot be said to have encroached upon turf of Parliament.
CIT Vs Indian Overseas Bank (Madras High Court) The question as to whether the date, on which the order under Section 147 of the Act was passed should be reckoned as the starting point of limitation, considering the facts and circumstances of the case, has been dealt with by several decisions of the Hon’ble Supreme […]
Jagadish Kumar Basantani Vs ITO Bhopal and Others (Madhya Pradesh High Court) Regard being had to the similitude of the questions involved, on the joint request of the parties, the matter is being heard on the question of admission and interim relief. Learned counsel for the petitioner submits that the petitioner has challenged the Constitutionality […]
CIT to at least record a prima facie finding that certain amount claimed by assessee as deduction in its computation of income de facto related to earning of dividend income. Thus, it was held that in the absence of any such prima facie finding, the reassessment was erroneous and no addition could be made under section 14A.
The Finance Act, 2021 introduced a new set of reassessment proceedings from 01.04.21.The Central Board of Direct Taxes (C.B.D.T) by way of various notifications had extended the time limit of issuing the notice U/s 148 of the Act up to 30th June, 2021. The Income tax department has issued many Section 148 notices for several […]
Palak Khatuja Vs Union Of India (Chhattisgarh High Court) 1. The time for issuance of notice under Section 148, the end date was initially extended uptill on 30th day of April 2021 and subsequently again by notification dated 27th April, 2021 the time limit of 30th day of April 2021 was further extended up till […]
Revenue authorities were restrained from continuing with reassessment till further orders with respect to notices issued on or after 1-4-2021 without following the procedure prescribed under section 148A in 79 cases.
Gujarat High Court observed that it cannot be said that there is no reason to believe that the income chargeable to tax has escaped assessment. The exercise of reopening has only been made after due inquiries and recording of statements of concerned persons and notice has only been issued after finding prima facie material.
