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 : Judicial rulings clarify that satisfaction for initiating action against other persons in search cases must be recorded promptly. ...
Income Tax : The High Court held that reassessment proceedings for AY 2013-14 were time-barred after computing the surviving limitation as clar...
Income Tax : Budget 2026 introduces sweeping retrospective amendments affecting limitation, reassessment jurisdiction, DIN validity, and TPO ti...
Income Tax : The new reassessment framework mandates enquiry, hearing, and a reasoned order before reopening. Courts now test jurisdiction on p...
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...
Corporate Law : Non- extension of the Time Barring Date for assessment of reopened cases and issuance of the notices for reopening – difficu...
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 ITAT Amritsar held that a valuation report by itself cannot justify addition under Section 69 without evidence of extra paymen...
Income Tax : The Court held that the petitioner had no connection with the entities or individuals from whose devices the disputed material was...
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 : 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 : CBDT directed that cases reopened u/s 147/148A in consonance with Judgement of SC in case of UoI vs. Ashish Agarwal & CBDT instruc...
Income Tax : Consequent to order passed by Allahabad High Court passing severe strictures and proposing to levy exemplary cost of Rs 50 lakhs i...
The Court set aside an assessment passed despite an existing stay order, holding that proceedings undertaken in violation of judicial restraint cannot stand.
The issue was whether reassessment could be initiated without material showing income had escaped assessment. The Court held that mere allegations of circuitous transactions were insufficient. The key takeaway is that actual escapement is mandatory under the amended law.
The Tribunal found that additions for securities transactions may overlap with amounts already accepted by the tax authority. The matter was remitted to the AO for factual verification before sustaining any addition.
The tribunal allowed a remand where unexplained cash deposits were added based on a PAN-linked account. The key takeaway is that effective opportunity must be given to disown alleged accounts.
The Tribunal held that reassessment notices issued by the jurisdictional officer violated the mandatory faceless regime under Sections 144B and 151A. Non-compliance with the prescribed faceless procedure renders the entire reassessment void ab initio.
The issue was whether reassessment can stand on an unsigned notice under Section 148. ITAT held that an unsigned notice confers no jurisdiction, rendering the reassessment void ab initio.
The issue was whether reassessment notices issued by the Jurisdictional AO were valid after the faceless regime. ITAT held that post-notification, only the Faceless AO could act, rendering the reassessment void.
The issue was whether a reassessment notice issued after 31.03.2021 for AY 2014-15 was within limitation. ITAT held the notice time-barred in light of the Supreme Court’s Rajeev Bansal ruling and quashed the entire reassessment.
The ruling declares reassessment void where notices were not issued through the faceless mechanism post-29.03.2022. Lesson: non-compliance with section 151A vitiates reopening.
The case addressed the legality of reopening an assessment when the notice was not issued through NFAC. Following jurisdictional High Court rulings, the Tribunal ruled that such deviation vitiates the entire reassessment process.
