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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 Delhi upheld deletion of ₹60 lakh addition after finding that the assessee furnished confirmations, audited financials, bank statements, and Section 133(6) replies. In absence of direct evidence linking loans to accommodation entries, the addition under Section 68 was held unsustainable.
The Tribunal held that statutory jurisdiction must be strictly followed in income-tax proceedings. In absence of proof of transfer to the assessing ward, the assessment was declared invalid and set aside.
The Tribunal held that failure to provide opportunity to cross-examine foreign information sources amounted to violation of natural justice. Additions based on unverified documents were therefore invalid.
The Tribunal ruled that incorrect computation of opening and closing stock during survey cannot justify full addition. Only the reconciled excess stock amount already offered to tax was sustained.
Where more than three years had elapsed, approval from the higher specified authority was compulsory before issuing notice. Failure to obtain such approval vitiated the reassessment proceedings.
Citing judicial precedents, the Tribunal held that failure to provide underlying material before passing order under Section 148A(d) invalidates reopening. The assessment order was consequently quashed.
The ITAT Mumbai held that reassessment notice issued beyond three years is invalid where alleged escaped income is below ₹50 lakh. Non-compliance with amended section 151 rendered the notice and entire proceedings void.
The Tribunal emphasized that approval from the correct specified authority is mandatory where reopening exceeds three years. Failure to comply rendered the reassessment proceedings void ab initio.
The Tribunal held that reassessment beyond four years is invalid where the assessee had fully disclosed material facts during original scrutiny. In absence of failure to disclose, reopening under Section 147 was quashed.
The ITAT held that approval under Section 151 was invalid as the PCIT merely noted As per Annexure without independent satisfaction. The reassessment under Section 147 was declared void ab initio.