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...
ITAT quashed the reassessments, agreeing with prior ruling that combined approval under section 148B for multiple assessees violates legal requirements.
The court reaffirmed that reassessment notices under Section 148 must be issued via the CBDT-prescribed automated system. Notices issued by local officers without allocation are considered without jurisdiction.
The Tribunal found that sanction must come from the Principal Chief Commissioner when reopening is beyond the three-year period prescribed by the amended law. Because the approval was taken from the Pr. CIT, the reassessment lacked jurisdiction and was invalidated.
Understand the statutory time limits for filings, applications, approvals, and settlement processes under the Income-tax Act, including key compliance deadlines.
The case examines whether a Section 148 notice issued after the extended limitation period was invalid. Key takeaway: approval beyond three years required the higher authority under Section 151(ii), making the notice vulnerable.
The High Court set aside reassessment notices for not following mandatory faceless procedures introduced by recent Finance Act amendments. The ruling underscores that non-faceless issuance violates statutory requirements.
High Court ruled that a writ challenging an order under Section 148A(d) is maintainable even when statutory appeals are available, emphasizing jurisdictional and legal issues.
ITAT Mumbai ruled that non-resident investments sourced from foreign salary cannot be treated as unexplained income, deleting ₹2 crore addition under Section 69.
The Tribunal ruled that authorities erred by ignoring the sale deed, receipt, and bank statements solely due to a technical lapse in return filing. Since the documents clearly established the source of cash, the addition could not survive. The order directed deletion of the section 69A addition.
The ITAT held that a reassessment notice issued beyond the six-year limitation under Section 149 is invalid. Key takeaway: Tax authorities must strictly comply with statutory time limits.
