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 : Explore the latest changes in Income Tax laws, including extinguishment of demands, return processing, form amendments, exemptions...
Income Tax : Discover the consequences of incorrect SFT reporting triggering U/s 148A notices under the Income Tax Act, 1961. Learn from a deta...
Goods and Services Tax : Explore the proposed penalties in Finance Bill 2024 for non-registration of machines under GST. Analysis of Section 122A and the i...
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 : Lucknow CA Tax Practicioners Association has made a Representation to FM for Extension of Time Limit for Assessment cases time bar...
Income Tax : DTPA has made a representation to Finance Minister, Smt. Nirmala Sitharaman and requested for for recalling notices under section...
Income Tax : Read the detailed analysis of Indira Ramaiah Vs ITO case by ITAT Bangalore. ITAT upheld the addition of gift for undisclosed inves...
Income Tax : In this case, Gudiyatham Muniraj Ashokkumaran challenged an assessment order, citing breach of natural justice principles due to i...
Income Tax : Gujarat High Court quashes Income Tax reassessment notice against Deepak Natvarlal Pankhiyani HUF, citing lack of fresh evidence s...
Income Tax : Assessee was engaged in diamond manufacturing, trading, and windmill power generation, had claimed deductions under sections 35DD ...
Income Tax : ITAT Raipur order on Rajesh Kumar Tiwari vs ITO. ITAT sets aside Income Tax reassessment completed without providing fair & reason...
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...
M/s Nishit Fincap Private Limited Vs ITO (ITAT Delhi) In this case The original assessment was completed u/s 143(3) on 03.12.2010 determining the total income at Rs.48,360/-. I find the assessment in this case was reopened on the basis of information obtained from the Investigation Wing, according to which, during the search and seizure operations […]
Gulmuhar Silk Pvt. Ltd. Vs ITO (Delhi High Court) Though it is the petitioner’s case that the impugned order is erroneous on facts, yet this Court is of the opinion that the petitioner would have ample opportunity during the course of proceedings before different statutory forums to show that the finding of fact arrived at […]
Vodafone Luxembourg 5 S A R L Vs Income Tax Department (Delhi High Court) Learned counsel for Revenue emphasises that the petitioner’s case has been selected for reassessment only on the ground that the respondents has doubted as to whether interest was received by the petitioner-assessee on rupee denominated bonds issued by an Indian company […]
Voltas Limited Vs ACIT (Bombay High Court) Facts- Petitioner is a company engaged in the business of air conditioning and refrigeration etc. During the A.Y. 2015-16, petitioner incurred expenses of Rs.3,30,82,713 towards CSR as per section 135 of the Companies Act, 2013. Petitioner had also claimed deduction in return of income u/s 35AC and 80G […]
It is well established that the reasons recorded by the AO cannot be further be substituted or added or deleted. We are of the view that the reference to market value of the flat as determined by stamp duty valuation authority also cannot justify initiation of reassessment proceedings under section 147 of the Act, as the validity of reassessment has to be tested only on the basis of reasons recorded by the Assessing Officer before issuing notice under section 148 of the Act and those reasons cannot be further improved.
Supreme Court has held that the expression ‘reason to believe’ means that there is some prima facie material on the basis of which the Department can reopen the case. The sufficiency or correctness of the material is not a thing to be considered at the stage of issue of notice under Section 148 of the Act.
Global Associates Vs DCIT (ITAT Bangalore) In the instant case, undisputed fact is that the assessee was not earlier assessed to tax for assessment year 2005-06 and hence no assessment order u/s 143(3) of the Act is available. In that situation, the provisions of section 151(2) of the Act is applicable to the facts of […]
J M Financial and Investment Consultancy Services Pvt. Ltd. Vs ACIT (Bombay High Court) HC held that since four years had expired from the end of the relevant assessment year, as provided under Section 151(1) of the Act, it is only the Principal Chief Commissioner or Chief Commissioner or Principal Commissioner or Commissioner who could […]
Raimaladitya Textile Pvt. Ltd. Vs ITO (Bombay High C0urt) The allegations in the reasons recorded are that as per information summary available to Revenue there is company by the name Raimaladitya Textile Pvt. Ltd., from whom bogus loan has been taken in F.Y. 2012-13 in the sum of Rs.40,88,06,800/- and the said Raimaladitya Textile Ltd., […]
Ranjana Aggarwal Vs ITO (ITAT Delhi) When the original assessment is completed u/s 143(3) and the reassessment proceedings have been initiated after a period of 4 years from the end of the relevant assessment year and there is no allegation of any failure on the part of the assessee to disclose fully and truly all […]
