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...
Gujarat High Court held that reassessment on the basis of information made available on Insight Portal without verification of information by jurisdictional Assessing Officer is invalid in law. Accordingly, writ disposed of.
The Court held that a reassessment notice generated on time but uploaded the next day is time-barred. Proceedings were set aside because despatch, not generation, determines the date of issuance.
Additions for alleged on-money payments were disallowed because the evidence relied on by authorities contained errors and lacked authenticity. The decision highlights the need for corroborated, primary evidence in tax proceedings.
The ITAT quashed the entire reassessment proceedings for AY 2015-16, observing that the foundational notice was issued after the permissible date. The ruling underscores that procedural timelines under TOLA cannot be extended retroactively. Subsequent orders based on the invalid notice were held without jurisdiction.
The Court quashed multiple notices and assessment orders for AY 2018-19, holding that procedural requirements under Section 151A were not met, while preserving Revenue’s right to revive proceedings.
Since valid service of notice was a mandatory jurisdictional requirement before initiating reassessment proceedings, therefore, purported notices issued under Section 148 including reassessment proceedings under
The High Court held that reassessment notices issued by the jurisdictional officer after the faceless regime came into force were without authority. All related proceedings were quashed, and the ITAT appeal was directed to be closed as infructuous.
SC disposes of Revenue SLPs; TOLA applies but reassessment timelines remain strictly enforced.
Tribunal invalidated the reassessment because the Assessing Officer failed to obtain mandatory approval from the specified authority under Section 151(ii), rendering the Section 148 notice void.
The reassessment notice under Section 148 issued after 01.04.2021 did not comply with the amended provisions requiring enquiry and hearing. The NFAC held the reassessment order void ab initio. This ruling emphasizes strict adherence to procedural safeguards under amended law.
