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...
The Finance Bill, 2021 after being passed by the Parliament and getting the assent of the President on 28th March 2021 has become the final law very much in force from 01 April 2021 of which each & every section is legally enforceable and applicable in toto.
Income tax department has issued notices u/s 148 for reassessment proceedings of previous financial years in the month of March-21. CBDT’s notification No. 20/2021, dated 31-03-2021, issued in exercise of the powers conferred by section 3(1) of the Taxation and Other Laws (Relaxation and Amendment of Certain Provisions) Act, 2020 (TLA Act, 2020) extended the last for issuance of notice u/s 148 up to 30.06.2021. However, the validity of the notices issued after 31.3.2021 is challenged in many High Courts by filing a writ petition.
Global Minimum Tax, Equlization Levy & Section 195, Section 9B & Section 45(4), New Judgements, Filing ITR & Tax Audit Report; Section 194Q & Section 206AB, New Registration of Trusts, Section 148 Notices & TDS/TCS Changes – vide Finance Act, 2021 Global Minimum Taxation 2 Pillar Approach – Pillar 1 Scope – 1. Multinational enterprises […]
Honourable Calcutta High Court too stayed the reassessment proceedings under section 148 read with section 148A , notices issued post 31/03/2021 and the notifications of extension of notices , following the ratio of the other HC judgements on similar issues . Interim order of STAY PASSED
Bagaria Properties and Investments Private Limited & Anr. Vs Union of India and Ors. (Calcutta High Court) The Court:-In this matter petitioners have challenged the impugned notices dated 29th May, 2021 and 18th June, 2021 relating to assessment years 2014-15 and 20 15-16 respectively under Section 148 of the Income Tax Act, 1961 on the […]
Mudra Finance Limited Vs ITO (Delhi High Court) Petitions have been heard by way of video conferencing. Present writ petitions have been filed challenging t he notices dated 09th June, 2021, 30th June, 2020 and 28th June, 2020 issued in W.P. (C) 6442/2021, 6443/2021 and 6451/2021 respectively by respondent No.1 under section 148 of the Income Tax […]
Notice U/S 143(2) Not Valid if Return Filed in Response to Notice U/S 148 Not Recognized by AO. Draft Written Submissions Written submission before the Hon’ble CIT(Appeals), XXXX bad in the case of Sh. XXXXXXXXXXX, XXXXXXX for the A.Yr. 2011-12. The assesse is an individual. He is doing business of trading of building material during […]
Sahil International Vs ACIT (Bombay High Court) 1. Mr. Jain, learned counsel for the Petitioner states that despite enforcement of the amended Income Tax Act, 1961 with effect from 01.04.2021, the Respondents purport to invoke repealed provisions of Section 148 of the Income Tax Act without following provisions of amended Act, issuing notice dated 07.06.2021. […]
Briefly, the issue concerns the applicability of the newly inserted provisions of Section 148A and the amendments brought inter alia in Section 149 of the Act. According to the petitioner, the proceedings should conform to the amended provisions.
Tata Communications Transformation Services Limited Vs ACIT (Bombay High Court) 1. Mr. Jehangir Mistri, learned Senior Advocate appearing for petitioner vehemently contends that the impugned notice under section 148 of Income Tax Act, 1961 in the present matter issued on 21/05/2021 is absolutely untenable on various grounds. He submits several provisions of the Income Tax […]
