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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...
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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 : Where unaccounted sales were established through seized material, only the net profit embedded therein was liable to tax, and not ...
Income Tax : ITAT Mumbai remanded the case to examine whether Section 56(2)(x) applied based on the agreement date and to consider refund of ex...
Income Tax : ITAT Bangalore remanded a Section 69A addition after holding that an APMC commission agent's entire sale proceeds could not be tre...
Income Tax : ITAT Kolkata condoned appeal delay, set aside the CIT(A)'s order, and remanded the assessment for fresh adjudication after grantin...
Income Tax : ITAT Mumbai quashed reassessment after finding no Section 143(2) notice and that the AO issued a final order disguised as a draft ...
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...
The Supreme Court has remitted reassessment cases for fresh consideration after the retrospective insertion of Section 147A, leaving its validity and constitutional challenge open for adjudication.
The ITAT held that a scrutiny assessment cannot survive where the jurisdictional Assessing Officer failed to issue the mandatory notice under Section 143(2). It ruled that the defect rendered the entire assessment void ab initio despite transfer of the case.
The ITAT held that payments made to directors represented arranger fees and not prohibited sub-brokerage under SEBI Regulations. It deleted the entire disallowance under Section 37(1), finding no violation of law.
The Tribunal ruled that an Investigation Wing report alone cannot justify an addition under Section 68 without independent verification by the Assessing Officer. It upheld the genuineness of the share transactions based on documentary evidence produced by the assessee.
The Tribunal distinguished between lack of enquiry and inadequate enquiry, holding that Section 263 cannot be invoked merely because the PCIT desired further verification. Since the AO had examined the evidence, the revisionary order was quashed.
The Tribunal ruled that a clerical mistake in the DRP’s order could not justify sustaining a ₹10 lakh addition. It held that the Assessing Officer should have implemented the DRP’s directions in substance and deleted the entire addition.
The ITAT Mumbai held that reassessment proceedings initiated on the basis of information arising from a search in the case of a third party fell within the exceptions to Section 148A. It ruled that issuance of a notice under Section 148A was without authority of law and could not confer jurisdiction. The reassessment was accordingly quashed.
The Bombay High Court held that proceedings under Section 153C were barred by limitation as the assessments were not completed within the statutory period. It quashed the notices issued for Assessment Years 2014-15 to 2019-20.
The Tribunal held that the reassessment was invalid because the Income Tax Officer lacked jurisdiction under CBDT Instruction No. 1/2011. The assessment was quashed, making examination of the additions unnecessary.
Tribunal held that allegations relating to client code modification did not justify adding the entire purchase value under Section 68 in the facts of the case. Following its earlier decision, it upheld taxation only of the profit embedded in the transactions.