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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...
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Income Tax : Supreme Court in the matter of Shri Ashish Agarwal, several representations were received asking for time-barring date of such cas...
Sh. Shambhu Dayal, Ravi Dutt, Gori Shankar Rajesh Rohit L/h Late Sh. Jhabar Mal (ITAT Jaipur) The undisputed facts are that the assessee, Shri Jhabar Mal Kumawat had expired on 10.10.2015 as noted by the AO in the assessment order. Thereafter, the reasons for reopening the assessment u/s 147 were recorded and after seeking approval […]
The issue under consideration is whether the re-opening of assessment u/s 147 of the Act is justified in law?
Naresh Kumar Garg Vs ACIT (ITAT Delhi) When the grounds for reopening the reassessment do not exist any longer and no additions were ultimately made on that account, the addition in respect of the other items, which were not part of the ‘ reasons to believe’cannot be made. ITAT states that it is evident that […]
1. Section 148(1) The CG may by order, in respect of class of companies engaged in the production of such goods or providing such services, direct that particulars relating to the utilization of material or labour or to other items of cost shall also included in the books of account kept by that class of […]
Whether the Tribunal was justified in holding that the reopening of assessment was a result of mere change of opinion, even when there is no opinion formed or expressed by the Assessing Officer on this issue in the original assessment?
The issue under consideration is whether the addition made by AO merely based on the statement recorded under section 132(4) of the I.T. Act is justified in law?
The issue under consideration is whether the AO is correct in re-opening of the assessment under section 147 even though the assessee has disclose fully and truly all the material facts during original assessment?
Aince the AO has accepted the returned income for which reasons were recorded, therefore, for making any other addition, he should have issued fresh notice
The issue under consideration is whether the re-opening of assessment u/s 147 on the basis of wrong appreciation of facts can be sustained in law?
Mr. Jay Kishor Mishra, IRS (IT: 1993) CIT (DR)(ITAT)-4, Delhi jkmishrairs@gmail.com Mr. Jay Kishor Mishra is an officer of the 1993 batch of the Indian Revenue Service. He is a Graduate in Economics and Post Graduate in Sanskrit. He is an LLB and also holds Post Graduate Diploma in Management. Ms Sushama Singh, IRS (IT: […]
