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...
HC held that Writ Court should not in exercise of its writ jurisdiction should substitute the findings of an assessing officer in his order with its own.
Lakshya Vintrade Private Limited Vs Union of India And Ors. (Calcutta High Court) The sole ground by the petitioner for challenging the impugned order under Section 148A(d) of the Act is that the same is not a speaking order and the reasons recorded therein are not well-reasoned and satisfactory which according to me cannot be […]
Gujarat High Court held that reopening of assessment sustainable on failure of true and full disclosure of demanded material on the part of the petitioner.
Bombay High Court held that in absence of any receipt of new information or reference to any new material on record, it can be concluded that re-opening of assessment is merely because of change of opinion and the same is unsustainable in law.
HC should not interfere in these types of cases where full-fledged investigations are required on alleged fictitious transaction/claim and all these are matters of evidence which cannot be appreciated by the writ court.
Rajasthan High Court held that reassessment resorted only on account of ‘Change of opinion’ of AO and without there being any fresh tangible evidence for reopening the assessment proceedings is liable to be struck down.
Bombay High Court held that re-opening of assessment under section 147 of the Income Tax Act is unjustified as the assessee provided complete disclosure of all the primary material facts during the scrutiny assessment.
ITAT Mumbai held that re-opening of assessment without ‘reason to believe’ simply based on the information from DGIT(Inv.) is untenable in law.
MA Multi-Infra Development Pvt. Ltd. Vs ACIT (Bombay High Court) On a perusal of the notice dated 31st March 2021 issued u/s.148 of the Act by the Assessing Officer shows that the same has been issued after obtaining necessary satisfaction of the Range 3(2), Mumbai. As per the objections filed by the revenue, the approval […]
Gujarat High Court held that issued raised in reopening assessment was already considered during assessment proceedings u/s 143(3) of the Income Tax Act. Accordingly, mere change of opinion by the Assessing Officer cannot be ground for reopening of assessment.
