Income Tax : Smt. Ranjana Kumari/Kalta Vs DCIT/ACIT (Central) (ITAT Chandigarh) The appeals involved three assessees belonging to the Kalta Gro...
Income Tax : Learn the updated provisions governing rectification, assessments, reassessments, and appeals under the Income-tax Act. This guide...
Income Tax : The article explains how the Finance Acts, 2025 and 2026 have reshaped the Updated Return regime under Section 139(8A). It highlig...
Income Tax : The Supreme Court has remitted reassessment cases for fresh consideration after the retrospective insertion of Section 147A, leavi...
Income Tax : This article explains why reassessment proceedings may be invalid if the Assessing Officer merely relies on Investigation Wing rep...
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 : Bombay HC quashed Section 148 notices, holding that search-based material required proceedings under Sections 153A/153C, not Secti...
Income Tax : Karnataka HC held Section 147 reopening invalid where seized material from a third-party search required proceedings under Section...
Income Tax : SC dismissed the SLP, leaving intact the HC ruling that Section 147 reopening was invalid where Section 153C procedure applied....
Income Tax : ITAT Kolkata upheld quashing of Section 148 reassessment, holding reopening on stale search material amounted to change of opinion...
Income Tax : Gujarat HC quashed reassessment and penalty orders issued against a deceased person, holding proceedings concluded against a dead ...
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...
While recording of the reasons to reopen an assessment, AO was required to form only prima Facie opinions about escapement of income as he was not making an assessment but taking a first baby step for making the assessment by forming a reasonable belief that whether the claim of assessee should be tested in reassessment proceedings or not. Thus, there was no infirmity in the action of AO that reasoned escapement of income by claiming deduction of Rs. 1 crore u/s 54EC.
Armada D1 Pte. Ltd. Vs DCIT (Bombay High Court) Notice under Section 148 stayed by Bombay High Court in view of conflict between new Income Tax Provisions for reopening of Assessment with Old Provisions On 3rd June Bombay High Court has stayed the operation of Notice under Section 148 dated 7th April 2021 for Assessment […]
CavinKare Pvt. Ltd. Vs DCIT (Madras High Court) It is the case of the petitioner that reopening of the assessment was based on the change of opinion for the year 2011-2012, and there was no ground for reopening of the assessment under Section 148 of the Income Tax Act for the purpose of Section 147 […]
Uttarakhand Purv Sainik Kalyan Nigam Ltd. Vs ITO (ITAT Dehradun) Reassessment on the basis of change of opinion, bad-in-law, more-so, when the case was re-opened after the expiry of four year and there was no non-disclosure which could be attributable to the assessee A) Re-opening of assessment on the same issue which was dealt during […]
1. Perface The Finance Act, 2021 with effect from 01st April, 2021 completely overhauled, renovated and re-regulated the provisions pertaining to section 147 of the Income Tax Act, 1961. Over a considerable period of time, the provisions of section 147 were subject matter of massive debates, dialogues and discussions with many a times, courts taking […]
Understanding the validity of Section 148 notices issued after April 1, 2021. Learn about the impact of the new provision and its implications.
1. Palaniammal Palaniappan Vs Income Tax Officer (Madras High Court), Case No : WP No. 12793 of 2018 And WMP No. 15016 of 2018, Dated : April 26, 2021 Reopening of assessment u/s 147 – assessee submitted that notice issued beyond the period of limitation of six years from the end of the relevant assessment […]
Sukhdev Singh Vs ITO (ITAT Delhi) As regards the contention of notice not properly served by the Assessing Officer, the explanation of the postal authorities is that the assessee has refused to take notice is a good service and hence ground Nos. 1 to 7 are dismissed. As regards ground Nos. 8 to 13, the […]
The property was conveyed to assessee after the death of his father in 1955, i.e. before coming into force of Hindu Succession Act, 1950. Accordingly, the property belonged to HUF of assessee and not to assessee-individual. Therefore, the assessment order passed under section 147 for difference in sale consideration and fair market value of property itself was liable to be quashed.
Prima Facie some material is required not sufficiency or correctness for valid reopening u/s 147 We have only to see whether there was prima facie some material on the basis of which the Department could reopen the case. The sufficiency or correctness of the material is not a thing to be considered at this stage. […]
