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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...
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 : 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 Court found no merit in interfering with the High Court’s order setting aside a belated reassessment notice. It confirmed that notices issued after the statutory limitation period are invalid.
The Tribunal restored the matter after holding that dismissal of the appeal without giving a chance to explain delay and cash deposits was not justified.
The Tribunal held that reassessment for AY 2015–16 was barred by limitation as the Section 148 notice was issued beyond the permissible period. It ruled that TOLA did not extend the time limit and the proceedings were void ab initio.
The new reassessment framework mandates enquiry, hearing, and a reasoned order before reopening. Courts now test jurisdiction on procedural compliance, not mere allegations of escaped income.
The Supreme Court confirmed that reassessment powers under Section 148 cannot be used to bypass the statutory scheme for search cases. The decision clarifies the distinct operating fields of Sections 153C and 148.
The Court held that reassessment based solely on material seized in a third-party search must proceed under Section 153C, not Section 148. Notices issued under the general reassessment provision were set aside.
The Supreme Court held that reassessment notices cannot be issued if limitation had expired under the old regime. The ruling affirms that the first proviso to Section 149 prevents retrospective reopening of assessments.
The Tribunal held that adverse regulatory findings alone cannot justify tax additions when client code modification trades are already recorded in the books and profits are disclosed.
The judgment clarified that information under Section 148A means a concise narration of alleged escapement, not complete material. The reassessment proceedings were allowed to continue as no jurisdictional defect was found.
ITAT ruled that property transferred under a bona fide family settlement is outside the scope of Section 56(2)(vii). Such arrangements are not treated as taxable gifts even if formalised through a gift deed.
