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 court held that reopening after four years based on a different view of the same expenditure amounts to a change of opinion. Absence of failure to disclose material facts made the reassessment invalid.
The ruling reiterates that reassessment after four years requires a clear failure by the assessee to disclose material facts. Absence of such failure rendered the notice unsustainable.
The court held that reopening beyond four years is invalid when the recorded reasons do not allege failure to disclose material facts. Full disclosure by the assessee barred reassessment.
The ruling confirms that reassessment based on investigation inputs cannot proceed without independent application of mind by the Assessing Officer. Prior scrutiny of share capital defeated the reopening.
The Tribunal held that profit estimation cannot rest on conjectures or lump-sum allegations. In absence of identified bogus purchases or factual basis, the entire addition was deleted.
The Tribunal ruled that non-compliance with the faceless reassessment scheme strikes at jurisdiction itself. JAO-issued notices post-notification were held legally unsustainable.
The High Court held that reassessment notices issued after excluding periods mandated by Supreme Court rulings were time-barred, rendering subsequent proceedings invalid
The Tribunal held that reassessment initiated after three years was void as approval was taken from an incompetent authority. The key takeaway is that failure to comply with section 151(ii) invalidates the entire reassessment.
The Court dismissed the appeal, holding that reassessment was justified as the original order contained no reference to the deduction claim. Mere filing of computation does not bar reopening.
The Court set aside reassessment proceedings after finding that the assessing officer failed to verify whether cash deposits were used to create a fixed deposit. The case was remanded for fresh consideration after proper examination.
