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 Hyderabad held that limitation for issuing notice under section 148 of the Income Tax Act would be only 3 years from the end of the assessment year since material suggesting escapement is less than Rs. 50 Lakhs. Hence, notice issued u/s. 148 is beyond period of limitation of three years hence quashed.
The tribunal refused to admit a fresh legal challenge to reassessment raised for the first time. However, it remanded the revenue-difference addition for fresh adjudication due to natural justice concerns.
Reopenings based on assumptions, conjecture, or generalized allegations were struck down. The ruling reiterates that reasons must show tangible material, application of mind, and a live nexus with escaped income.
The Tribunal upheld deletion of unsecured loan additions after finding that the lenders identity, bank trail, and reserves were established. Low declared income alone was held insufficient to treat the credits as unexplained.
The Assessing Officer treated all cash deposits as unexplained income under Section 115BBE. The Tribunal held that deposits prima facie represented IOC sales and required factual verification before any addition.
The dispute concerned whether transfer through a release deed amounted to a taxable sale and justified loss claims. The Tribunal remanded the matter, directing verification of books to examine the genuineness of the claimed loss.
The issue concerned reassessment initiated through a non-faceless notice despite a binding notification. The ruling confirms that violation of the faceless framework vitiates reassessment proceedings.
The Tribunal held that reassessment based on a notice issued by the wrong authority cannot survive in law. The decision highlights strict adherence to procedural requirements under the faceless regime.
The Tribunal held that reassessment remains valid when the notice is issued while the company is still on the ROC records. Subsequent striking off does not nullify initiated proceedings.
The court held that a reassessment notice issued by the jurisdictional officer violated the faceless assessment scheme. As a result, the notice and the consequential assessment order were set aside, subject to liberty if higher courts take a different view.
