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...
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 […]
ACIT Vs M/s Goldmohur Design and Apparel Park Ltd. (ITAT Mumbai) Under the new provisions of section 147, an assessment can be reopened if the Assessing Officer has ‘reason to believe’ that income chargeable to tax has escaped assessment; but if he wants to do so after a period of four years or merely on […]
Ajay Narayan Bhoir Vs ACIT (ITAT Mumbai) In case of return of income processed under section 143(1), the only condition to be satisfied for reopening is that taxable income has escaped assessment and the assessee’s plea that no fresh material was there before the AO warranting re-opening, was not relevant. FULL TEXT OF THE ITAT […]
