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...
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.
The Tribunal ruled that once the assessee responds to a 148A(b) notice, the AO must complete the 148A(d)–148 cycle within the remaining time. In this case, the notice overshot the surviving limitation period, making reassessment legally defective. Consequently, all additions related to alleged accommodation entries and loans were quashed.
ITAT quashed reassessment notice issued by Jurisdictional AO instead of Faceless AO. Addition of ₹29.69 crore was invalidated, and Revenue’s appeal became infructuous.
The Gujarat High Court held that a notice issued under Section 148A(b) was procedurally flawed as it functioned as a Section 148A(a) inquiry. The notice, order under Section 148A(d), and subsequent notice under Section 148 were quashed.
Bombay High Court held that reopening of assessment proceedings on the basis of change of mind/opinion and also on non-application of mind is liable to be quashed and set aside. Accordingly, impugned notices and order quashed.
ITAT held that post-29.03.2022, notices must be issued faceless; issuance by JAO violated law, invalidating the reopening and assessment.
The tribunal ruled that reassessment notices issued after April 2021 for AY 2015-16 are invalid, as they fall outside TOLA provisions and are time-barred.
Karnataka High Court quashed several notices, assessment orders, and bank garnishments issued under sections 148A, 147, 156, and 226(3), allowing the cooperative federation’s petition.
