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...
ITAT held that though Section 151A was on statute, it required notification to take effect. As the order preceded notification, the assessment was quashed in entirety.
The Tribunal found repeated factual errors in recorded reasons and notices. As the reopening lacked live nexus with escapement of income, it was struck down as a nullity.
The ITAT Kolkata held that cash introduced by partners as capital contribution in an LLP does not attract Section 269SS and therefore penalty under Section 271D was invalid.
ITAT ruled that mere reference to high-value transactions cannot justify reopening beyond three years. Absence of statutory conditions under Section 149(1)(b) rendered the reassessment void.
ITAT held that for reassessment beyond three years, approval must be obtained from the PCCIT under Section 151. Sanction from PCIT was held invalid, rendering the notice and assessment void.
The ITAT Mumbai deleted the ₹14.70 lakh addition made under Section 69, holding that the NRI assessee had adequately explained the source of investment in property through documented overseas remittances routed partly via his mothers bank account.
ITAT held that mere signature or rubber-stamp approval under Section 151 is invalid if it does not reflect independent satisfaction. The reassessment and consequent additions were quashed for lack of valid jurisdiction.
The Tribunal reaffirmed that providing PAN, confirmations, bank statements, and financial records satisfies statutory requirements. With no defects found by the AO, the addition was rightly deleted.
The Tribunal ruled that reopening of assessment is void where the notice under Section 148 was issued prior to communication of sanction under Section 151. Such procedural lapse renders the entire reassessment null and void.
TAT Kolkata ruled that reopening based on unverified foreign information amounted to borrowed satisfaction. Since the sanctioning authority granted approval mechanically, the reassessment was declared void.
