Income Tax : Learn the updated provisions governing rectification, assessments, reassessments, and appeals under the Income-tax Act. This guide...
Income Tax : The article explains how the Finance Acts, 2025 and 2026 have reshaped the Updated Return regime under Section 139(8A). It highlig...
Income Tax : Learn how different types of income tax assessments are conducted under the Income-tax Act. The FAQs explain assessment procedures...
Income Tax : This article explains why reassessment proceedings may be invalid if the Assessing Officer merely relies on Investigation Wing rep...
Income Tax : A detailed overview of limitation periods prescribed under the Income-tax Act reveals how missing statutory deadlines can lead to ...
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 : Madras HC held that merely issuing a corrigendum acknowledging the return did not rectify the defective assessment process and ord...
Income Tax : ITAT held reassessment under Sections 147/148 invalid because it was based on a pre-1 April 2021 third-party search, requiring pro...
Income Tax : ITAT Mumbai quashed a Section 148 notice issued after the limitation under the first proviso to Section 149, holding the reassessm...
Income Tax : Gujarat HC quashed the reassessment proceedings after holding that ignoring the assessee's adjournment request violated natural ju...
Income Tax : ITAT Kolkata held that extensive documentary evidence, audited books, supplier confirmations and banking records established the g...
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...
Budget 2026 introduces sweeping retrospective amendments affecting limitation, reassessment jurisdiction, DIN validity, and TPO timelines. The changes directly impact ongoing appeals, rectification, revision, and reassessment proceedings, altering litigation strategy for taxpayers and authorities alike.
The Tribunal quashed the reassessment as the notice issued beyond three years failed to satisfy mandatory conditions under Section 149(1)(b). It held that absence of proper jurisdictional facts and compliance rendered the reopening invalid.
The Court granted interim relief after noting absence of proof that mandatory approval under Section 151 was served on the assessee. It held that the petitioner had made out an arguable case warranting stay of the Section 148 notice.
The Tribunal held reassessment invalid as approval was taken from Pr. CIT instead of Pr. CCIT under Section 151(ii). Jurisdictional non-compliance rendered the notice void.
The Tribunal held that the reassessment notice was time-barred under the Supreme Court ruling on surviving period. Notices issued beyond the permissible limit were declared invalid.
ITAT Mumbai quashed reassessment beyond 3 years as escaped income was ₹37.76 lakh (<₹50 lakh) and approval u/s 151 was wrongly granted by PCIT, rendering notice u/s 148 void.
The Tribunal ruled that reopening beyond three years requires approval from higher specified authorities under Section 151. Since approval was taken from an incorrect authority, the reassessment was declared void.
Relying on the Supreme Court ruling in Rajeev Bansal, ITAT ruled that proper sanction is mandatory under the new reassessment regime. Non-compliance with Section 151 rendered the notice and subsequent proceedings void ab initio.
The ITAT Mumbai held that reassessment initiated beyond three years was invalid as approval under Section 151 was granted by the Principal Commissioner instead of the statutorily required Principal Chief Commissioner or equivalent authority.
ITAT Bangalore quashed reassessment for AY 2017-18, holding notice issued on 12-04-2024 time-barred under first proviso to Sec.149(1), despite prior 148A proceedings.
