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Income Tax : Learn the updated provisions governing rectification, assessments, reassessments, and appeals under the Income-tax Act. This guide...
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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...
ITAT Mumbai deleted ₹6.15 lakh penny stock LTCG addition, holding investigation report and abnormal price rise insufficient without direct evidence linking assessee to accommodation entries.
ITAT Mumbai quashed reassessment beyond 3 years as escaped income was ₹37.76 lakh (<₹50 lakh) and approval u/s 151 was wrongly granted by PCIT, rendering notice u/s 148 void.
Reassessment based solely on investigation inputs about penny stocks was rejected. The Tribunal held that documented transactions through bank and demat accounts sufficiently explained the investment source.
The Tribunal ruled that reopening beyond three years requires approval from higher specified authorities under Section 151. Since approval was taken from an incorrect authority, the reassessment was declared void.
Relying on the Supreme Court ruling in Rajeev Bansal, ITAT ruled that proper sanction is mandatory under the new reassessment regime. Non-compliance with Section 151 rendered the notice and subsequent proceedings void ab initio.
The Tribunal found inconsistencies in the CIT(A)’s findings while restricting addition to 12.5% of purchases. As key facts were not properly examined, the issue was restored for fresh adjudication.
ITAT deleted ₹60 lakh addition as the Revenue relied solely on a third-party confession without independent verification. Documentary evidence such as confirmations, ITRs and bank statements discharged the assessee’s onus.
ITAT ruled that once the Assessing Officer makes no addition on the issue forming the basis of reopening, other additions cannot survive. MAT demand under Section 115JB was therefore struck down as unlawful.
ITAT quashed reassessment as approval under Section 151 was granted by PCIT instead of PCCIT. Notice issued after three years was held void for lack of proper jurisdiction.
ITAT ruled that mere endorsement stating “Yes, I am satisfied” does not constitute valid sanction under Section 151. Mechanical approval without independent application of mind invalidated the reassessment.
