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Income Tax : Humble Representation for modification of Section 151 of the Income Tax Act relating to Sanction for issue of Notice under sec. 14...
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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 ...
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Income Tax : Supreme Court in the matter of Shri Ashish Agarwal, several representations were received asking for time-barring date of such cas...
The Tribunal held that reassessment was invalid as the statutory sanction under Section 151 was granted mechanically. Mere use of the word Approved does not show application of mind and vitiates the entire proceedings.
The Tribunal held that sanction for reopening was granted mechanically and without independent application of mind, as required under Section 151. An undated and non-speaking approval vitiated the entire reassessment proceedings.
Failure to demonstrate a dated approval under Section 151 proved fatal to the Revenue’s case. The decision underscores strict compliance in reopening assessments.
The assessment was set aside as the Revenue produced no acknowledgment of service. The ruling reiterates that service of notice is foundational to reassessment.
The Tribunal held that reassessment under Sections 147/144B is void if no notice under Section 143(2) is issued. Acting on a return filed or adopted in response to Section 148 triggers mandatory jurisdictional compliance.
The court held that reopening an assessment on the same facts amounts to an impermissible change of opinion. Arbitrary second reassessment notices were quashed with ₹1 lakh costs imposed to deter harassment.
The tribunal ruled that reassessment notices for AY 2015-16 issued after 31 March 2022 are barred by limitation. The key takeaway is that TOLA extensions do not apply to this assessment year.
The Tribunal held that assessments under Section 153A cannot be sustained when no incriminating material is found at the assessees premises. Additions based on third-party material were quashed as being without jurisdiction.
The Tribunal ruled that treating a belated return as non est is legally unsustainable. Absence of a Section 143(2) notice invalidates the entire reassessment proceedings.
The Tribunal held that a continuously maintained ledger found during search constituted reliable evidence. Additions for unexplained expenditure under section 69C were sustained based on corroborated diary entries.
