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...
Mehrunnisa Mohamed Fazal Maniar Vs ITO (Gujrat High Court) The case on hand is not a case where the Income Tax Officer seeks to draw any fresh inference which could have been raised at the time of the original assessment on the basis of the materials placed before him by the assessee relating to the […]
Jagdish U. Thackersey Vs DCIT (ITAT Mumbai) It is well settled that mere fresh application of mind to the same set of facts or mere change of opinion does not confer jurisdiction even under the post-1989 section 147. The consistent view is that even after amendment of section 147 (w.e.f. 01.04.1989) mere change of opinion […]
Kantibhai Dharamshibhai Narola Vs ACIT (Gujarat High Court) (i) The Court should be guided by the reasons recorded for the reassessment and not by the reasons or explanation given by the Assessing Officer at a later stage in respect of the notice of reassessment. To put it in other words, having regard to the entire […]
Sujay Pankajbhai Shah Vs ACIT (ITAT Ahmadabad) A bare glance of the reasons recorded gives an unflinching impression that powers exercised under section 147 of the Act was to enable the AO to carry out detailed verification of the various aspects of such matter in reference made to the AO herein by the office of […]
AO had recorded incorrect, wrong and non-existing reasons for reopening of the assessment and also failed to verify the information received by him before recording the reasons for reopening of the assessment. Thus, there was clearly non-application of mind on the part of AO to initiate the re-assessment proceedings. Thus, the reopening of assessment could not be sustained in Law.
Narendra Kumar Gill Vs ITO (ITAT Delhi) Moot issue to be decided is whether mentioning the PAN of another entity mistakenly instead of the PAN of the assessee makes the notice issued u/s 148 invalid or not when the notice is addressed to Shri Narendra Kumar Gill and the body of the notice clearly reflects […]
Nilesh Ajit Kumar Jain Vs ITO (ITAT Mumbai) A perusal of the assessment order shows that the assessment was reopened to examine misuse of Client Code Modification for tax evasion. No addition was made by the Assessing Officer in respect of the issue for which the assessment was reopened. It is a well settled law […]
Maheshwari Roller Flour Mills Pvt. Ltd. Vs ITO (ITAT Delhi) Learned Counsel submitted that initiation under section 147 of the I.T. Act have been done by mentioning the wrong Section 147(b) of the I.T. Act which is deleted from the Income Tax Act w.e.f. 01.04.1989, therefore, reopening is done under non-existent Section in a mechanical […]
Admach Auto Limited Vs DCIT (ITAT Delhi) Disposal Of Objection To Reasons In Assessment Order Itself Without Separate Speaking Order Makes Entire Reassessment Invalid We have also gone through the objections dated 27.12.2016 filed by the assessee before the AO in which the assessee has specifically objected the initiation of proceedings u/s. 148 of the […]
Dart Infrabuild (P) Ltd. Vs ITO (ITAT Delhi) A conjointly reading of section 148 (1) of the Act with section 139 (4) of the Act and section 144 of the Act makes it abundantly clear that pursuant to the notice under section 148 of the Act, if an assessee files a belated return or letter […]
