Income Tax : Explore how electronic data transforms tax assessments, highlighting accuracy issues, verification needs, and taxpayer rights as s...
Income Tax : Learn about the revised procedure for reopening cases under Section 148 RWS 135A and the implications of Finance Act 2021, includi...
Income Tax : Discover the key amendments in the Finance (No.2) Bill, 2024, affecting income tax reassessment procedures under the Income-tax Ac...
Income Tax : Explore the Bombay High Court's ruling on the invalidity of a reassessment notice under Section 148 of the Income-tax Act, 1961, f...
Income Tax : Explore the legality of issuing a second notice under Section 148 of the Income Tax Act, 1961 for the same assessment year. Unders...
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 High Court held that issuance of notice under section 148A of the Income Tax Act by Jurisdictional Assessing Officer and no...
Income Tax : ITAT Kolkata held that CIT has not applied his mind analytically while assuming jurisdiction for taking cognizance under section 2...
Income Tax : ITAT Pune restored the assessment order as assessee neither filed any evidence nor provided material in an attempt to discharge th...
Income Tax : Delhi High Court held that reassessment action under section 148 of the Income Tax Act post approval of the resolution plan unsust...
Income Tax : Patna High Court held that for migrating PAN to new AO, due to change in address, a written request to existing AO must be made. S...
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...
Corporate Law : Income Tax Gazetted Officers’ Association (W.B.) Unit Date: 02.02.2023. To The Principal Chief Commissioner of Income Tax, W...
Income Tax : Consequent to order passed by Allahabad High Court passing severe strictures and proposing to levy exemplary cost of Rs 50 lakhs i...
Vinod Fabrics Private Limited Vs ACIT (Gujarat High Court) Gujarat High Court quashes Section 148 notice along with order under section 148A(d) for AY 2014-15, Post SC decision in UOI vs. Ashish Agrawal FULL TEXT OF THE JUDGMENT/ORDER OF GUJARAT HIGH COURT 1. The petitioner seeks to challenge the notice issued under Section-148 of the […]
Taru Pallav Projects Pvt. Ltd. Vs ITO (Gujarat High Court) Hon. Gujarat High Court quashes Section 148 notice along with order under section 148A(d) for AY 2013-14, Post SC decision in UOI vs. Ashish Agrawal 1. The petitioner seeks to challenge the notice issued under Section-148 of the Income Tax Act, 1961 dated 30.06.2021. In […]
Subsequent amendment to section 149, by Finance Act, 2012 which extended limitation for initiation of reassessment proceedings to sixteen years could not be resorted for reopening concluded proceedings and the notice issued under Section 149 was time barred and thus could not have been acted upon. Consequently, the impugned re-assessment order passed in consequence of the illegal notice under Section 148 was a nullity and bad in law.
Supreme Court in the matter of Shri Ashish Agarwal, several representations were received asking for time-barring date of such cases, in the light of communication sent by ITBA. The Board is of the view that such cases have to be completed by 31.05.2023
In cases where a search under section 132 is initiated or a search for which the last of the authorization is executed or requisition is made under section 132A, after the 15th March of any financial year a period of fifteen days shall be excluded for the purpose of computing the period of limitation for issuance of notice under section 148 and the notice so issued shall be deemed to have been issued on the 31st day of March of such financial year.
Pawan Kumar Agrawala Vs Income Tax Officer (Orissa High Court) The Chief Justice bench of Orissa High Court, of late has not been entertaining writ petition against notice u/s 148 in view of the decision of the Supreme Court in the case of Anshul Jain. This is notwithstanding the fact that on 1st February 2023, […]
HC set aside reassessment order against assessee, for non-supply of information/ material by Revenue Department for reopening of assessment.
Draft submission to ITAT when AO doesn’t comply with section 147 to 151 of Income Tax. Ground of Appeal & Arguments in writing, AO’s reasons recorded u/s 148(2) were never supplied to assessee. Assessment bad in law & spirits as reopening bad enough.
Income Tax Gazetted Officers’ Association (W.B.) Unit Date: 02.02.2023. To The Principal Chief Commissioner of Income Tax, West Bengal & Sikkim Region, Kolkata. Sir, Sub: Time barring date for reopening cases arising out of the direction of the Hon’ble SC in the case of Ashish Agarwal-matter regarding. Your kind attention is invited to the minutes […]
According to HC, the central issue, to which the Assessing Officer (AO) should have applied his mind is, as to whether the investment in shares of Agile by the petitioner was a capital account transaction, given the fact that there is no allegation of round-tripping.
