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 Chandigarh held that a Section 148 notice issued by the Jurisdictional AO instead of Faceless AO violated statutory provisions, quashing the assessment for AY 2016-17.
The Tribunal held that reassessment under Section 148 was invalid as the notice was issued by the Jurisdictional Officer instead of the Faceless Assessing Officer, affirming the CIT(A)’s order.
Reassessment proceedings initiated without obtaining prior approval from the appropriate “specified authority” under Section 151(ii) such as the Principal Chief Commissioner of Income Tax or the Principal Director General were invalid.
AO must apply their own mind to the contents of the DVO report and any other available material as relying solely on a DVO’s report without any independent inquiry or satisfaction was a fundamental jurisdictional flaw that invalidated the entire reassessment proceeding from the start.
Delhi High Court set aside notice under Sections 148A(3) & 148 when petitioner’s objections and documents were not considered before reopening for AY 2019-20.
Delhi High Court held that reassessment proceedings for AY 2014–15 were time-barred and quashed notices and orders issued under Sections 148 and 148A.
The Delhi High Court set aside reassessment notice and order against Sarthak Gupta for AY 2014–15, citing the Supreme Court’s ruling in Rajeev Bansal.
The Allahabad High Court directed tax authorities to give assessees a chance to object before reassessment, reaffirming principles from GKN Driveshafts v. ITO.
Bombay High Court held reassessment invalid for A.Y. 2017–18 as approval was obtained from the Principal Commissioner instead of the higher authority required under Section 151(ii).
The Tribunal held that the notice u/s 148 issued without prior approval of the specified authority under Section 151(ii) is invalid. The reassessment order for AY 2017-18 was quashed.
