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 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 : Court upheld the validity of the Section 148 notice but set aside the assessment order after finding that notices were sent to an ...
Income Tax : Tribunal reiterated that credits brought forward from earlier financial years cannot ordinarily be taxed under Section 68 in subse...
Income Tax : The Delhi High Court held that reassessment proceedings cannot be sustained on changing allegations introduced after issuance of n...
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 issue was whether reassessment notices issued after the permissible surviving period were valid. The Court held they were time-barred and quashed them, reinforcing strict adherence to limitation rules.
Gujarat High Court held that reopening of assessment u/s. 147 of the Income Tax Act solely on the basis of material found by AO of searched person without satisfaction note as prescribed under section 153C is untenable in law.
ITAT Hyderabad held that notices under Section 148 issued on 01.04.2021 without following mandatory Section 148A procedures are invalid. The Tribunal quashed reassessment orders, emphasizing that procedural compliance is jurisdictional and essential.
The High Court quashed a reassessment for A.Y. 2015–16 where the Section 148 notice was issued after 1 April 2021. Relying on the Revenue’s binding concession before the Supreme Court, all consequential actions were set aside.
The issue was whether a notice dated 31-03-2021 but digitally signed on 01-04-2021 was valid. The ITAT held the notice was issued under the new regime without following section 148A, rendering reassessment void.
The case examined whether reassessment proceedings could survive when issued outside the faceless mechanism. The ruling confirms that non-compliance with the faceless scheme is a fatal jurisdictional defect.
The issue was whether reassessment can continue when all notices are issued in the name of a deceased assessee. The Tribunal held such proceedings void ab initio, as jurisdiction ceases upon death.
The issue was whether the appellate authority could delete a large unexplained investment without following Rule 46A. The Tribunal held that bypassing mandatory procedure invalidates the relief, and the matter must be re-examined.
The Tribunal held that reassessment initiated after three years was void because approval was taken from an incompetent authority. The key takeaway is strict compliance with section 151(ii) is mandatory and jurisdictional.
This explains why recent income disclosure intimations lack statutory support and create uncertainty. The key takeaway is that vague communications without cited legal provisions may not withstand legal scrutiny.
