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 Tribunal quashed reassessment proceedings where the section 148 notice and section 148A(d) order were issued by the JAO instead of the FAO. It reaffirmed that post-notification violations of the faceless scheme cannot be cured by participation or waiver.
The ITAT held that reassessment notices issued by a JAO after 29.03.2022 are void, as only a Faceless Assessing Officer can act under the faceless regime.
The Tribunal held that a notice issued under section 148 on 31.07.2022 for AY 2014-15 was barred by limitation under the amended section 149. Reassessment proceedings were quashed as void ab initio.
Applying a liberal approach, the tribunal condoned delay in appeal filing and examined the jurisdictional defect. Since reopening was initiated by the wrong authority, the assessment could not survive.
he tribunal held that reassessment notices issued by the jurisdictional assessing officer instead of the faceless authority violate the mandatory faceless assessment framework. Such jurisdictional defects render the entire reassessment proceedings void ab initio.
The issue was whether penalties under sections 271D and 271E apply to cash dealings of a credit society with its members. ITAT held that genuine, audited member transactions supported by reasonable cause are protected under section 273B.
Chennai ITAT held that reassessment notices issued by a JAO after 29-03-2022 are invalid under the mandatory faceless assessment framework, quashing all consequential orders while preserving the Revenue’s right to revive proceedings if Apex Court rules otherwise.
The issue was whether reassessment could survive when sanction under section 151 was taken from the wrong authority. The Tribunal held that approval by the PCIT instead of the PCCIT/PDG is a fatal jurisdictional defect, invalidating the entire reassessment.
ITAT Delhi held that Section 148 notices issued with approval from an incorrect authority are invalid. Reassessment orders for AYs 2016-17 and 2017-18 were quashed.
Uttarakhand High Court held that order of the Competent Authority granting sanction or approval or refusing to grant sanction or approval u/s 151 of the Income Tax Act of 1961 is neither a revisable order, nor an appealable order.
