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...
FIS Global Business Solutions India Pvt. Ltd. Vs PCIT (Delhi High Court) Reliance by the Revenue upon an audit report, cannot be considered as tangible material. This Court is of the opinion that Carlton Overseas Pvt. Ltd. v. Income Tax officer & Ors., (2009) 318 ITR 295 concludes the issue in the present case; the audit objection […]
A. Sridevi Vs ITO (Madras High Court) Admittedly, the original return filed by the assessee did not reflect the subject matter income, namely, the advance made by the assessee to the said Nagarajan of a sum of Rs.2.75 crores. When the earlier reopening proceedings was initiated with issuance of notice under section 148, the assessee […]
ITO Vs Aggregate Finance & Investment P. Ltd (ITAT Delhi) Be that as it may, as adverted to supra, the case of the Ld. AO while recording the reasons was that the assessee derived the income as a provider of bogus accommodation entries. However, the addition was made on account of receipt of share application […]
Reopening of assessment beyond four years merely on the basis of information received, however, without pointing out failure of assessee to furnish truly and fully all material facts was not valid.
Validity of Reassessment Notice under section 148-Where approval of Addl. CIT was not obtained to reopen the assessment, rather it was obtained from CIT, the same was in breach of section 151.
Shanta Kapoor Vs ACIT (ITAT Agra) If AO omits to issue notice under section 148 of Income Tax Act, 1961 to all legal representative (LRs) of deceased assessee, the reassessment would be null and void. Assessee ‘deceased’ had 3 legal heirs, two being sons and one daughter. The AO had not issued notices to all the […]
Honda Motor Co. Ltd. Case: Where Reassessment Is Based Only On Allegation That Appellant Has PE In India, Notice Under Section 148 Cannot Sustain Once Arm’s Length Price Procedure Has Been Followed.
PCIT Vs FIS Global Business Solutions India Pvt. Ltd (Delhi High Court) In the present case, the reassessment notice is solely based on an audit opinion. Having regard to the fact that the assessee’s challenge to the previous year’s re-assessment orders was successful – in FIS Global Business Solutions India Pvt. Ltd. v. ACIT 2018 (408) […]
Soniya Gandhi Vs ACIT (Supreme Court of India) Supreme Court of India has allowed Income Tax Department to reopen tax case against Congress leaders Sonia Gandhi and Rahul Gandhi for A.Y. 2011-12 in connection with National Herald case. Hon’ble Supreme Court has held as follows:- “For certain reasons, it is not possible to take up […]
Shri Sudhir Menon Vs ACIT (ITAT Mumbai) The assessee filed return of income under section 148 of the Act vide letter dated 23.05.2013 stating that the original return of income can be treated as return filed in response to notice under section 148 of the Act. It means that the assessee has filed return of […]
