Income Tax : ITAT Mumbai held that an addition under Section 69A cannot be sustained when the assessee is denied the opportunity to cross-exami...
Income Tax : ITAT held that additions based solely on third-party search material without independent evidence or cross-examination are invalid...
Income Tax : ITAT held that a return filed under section 148 remains valid even if delayed. Failure to issue mandatory notice under section 143...
Income Tax : Judicial rulings clarify that satisfaction for initiating action against other persons in search cases must be recorded promptly. ...
Income Tax : The Finance Bill 2026 proposes allowing taxpayers to file an Updated Return even after receiving a reassessment notice under Secti...
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 : ITAT Indore held that appellate order violated principles of natural justice after finding that key hearing notices were sent to a...
Income Tax : Court ruled that reassessment notices under Section 148 must be issued through the faceless mechanism under Section 151A and the 2...
Income Tax : The Madras High Court held that reassessment notices required to be issued by the Faceless Assessing Officer are invalid if issued...
Income Tax : The Madras High Court held that reassessment notices required to be issued by the Faceless Assessing Officer are invalid if issued...
Income Tax : The Jharkhand High Court held that retrospective insertion of Section 147A removed the jurisdictional challenge against reassessme...
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 appellate authority had mechanically rejected additional evidence without reasons, resulting in denial of fair opportunity. The tribunal restored the quantum issue for reconsideration and quashed the consequential penalty.
Applying the timelines prescribed in Rajeev Bansal, the Tribunal found the notice issued after the permissible window. The ruling reinforces strict adherence to limitation in reassessment cases.
The Tribunal held that a notice dated 31.03.2021 but dispatched after 01.04.2021 is governed by the new reassessment regime. Failure to follow section 148A procedures rendered the entire reassessment void.
ITAT Pune held that provision of interest on loan from state government is ascertained liability and hence couldn’t be disallowed under section 37 of the Income Tax Act. Accordingly, the appeal is allowed.
The Assessing Officer proceeded with reassessment after three years based solely on PCIT approval. The Tribunal emphasized that compliance with Section 151 is mandatory, and failure renders the notice under Section 148 void.
Reassessment was quashed as the statutory process under the faceless regime was not followed end-to-end by the same authority. Such jurisdictional inconsistency vitiates the entire proceedings.
The Tribunal held that reassessment initiated solely on a Revenue audit objection, without fresh tangible material, is invalid. Reopening beyond four years on the same facts examined earlier amounts to impermissible change of opinion.
The ITAT Chennai held a reassessment notice under section 148 invalid as it was issued after the statutory limitation expired, emphasizing strict compliance with time limits.
The Tribunal held that reassessment under section 147 fails when seized search material exists. The correct and exclusive route is section 153C, making the reopening jurisdictionally invalid.
The Tribunal ruled that taxing entire bank cash deposits under section 69A without examining business explanations is unsustainable. The reassessment was restored for de-novo adjudication with conditions.
