Income Tax : Explore the latest changes in Income Tax laws, including extinguishment of demands, return processing, form amendments, exemptions...
Income Tax : Discover the consequences of incorrect SFT reporting triggering U/s 148A notices under the Income Tax Act, 1961. Learn from a deta...
Income Tax : The Income-tax Act has prescribed time limit in respect of various procedures, applications, etc. (like time limit for filing an a...
Income Tax : Explore legality of Section 148A(b) & Section 148A(d) proceedings post Finance Act 2021. Understand implications of local assessm...
Income Tax : Understand the critical role of the initial enquiry under Section 148A(a) for taxpayer protection in income tax assessments. Explo...
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 : Discover the ITAT Chennai verdict on Santhilal Jain Vijay Kumar Vs ITO, addressing taxation on excess stock and unexplained marria...
Income Tax : The court held that while the information prompting the notice must be disclosed to the assessee, the detailed material or evidenc...
Income Tax : Read the Kerala High Court's judgment setting aside an Income Tax Act Section 148(A) order due to lack of opportunity for hearing....
Income Tax : Telangana HC sets aside reassessment notices under Section 148 for not following the modified procedure of Finance Act 2021. Inval...
Income Tax : Gauhati High Court rules that AO names cannot be reflected in notices issued under Section 148 in a faceless manner, reaffirming p...
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...
Income Tax : Salient features of new Section 148 to 151A 'i.e. assessment/reassessment procedure of Income Escaping Assessment...
Notice under section 148 of Income Tax Act, 1961 without following the procedure under section 148A issued during 01.04.2021 to 30.06.2021 in relation to AY 2014-15 or earlier assessment years. A Controversy By way of various notifications issued under section 3 of the Taxation and Other Laws (Relaxation and Amendment Of Certain Provisions) Act, 2020 […]
Time period for issuance of notice under section 148 under new regime wef 1.4.2021. As per substituted section 149 wef 1.4.2021 As per substituted section 149, no notice shall be issued for the relevant assessment year if: (a) 3 years have elapsed from the end of the relevant assessment year, unless the case falls under […]
The Finance Act, 2021 introduced a new set of reassessment proceedings from 1st April 2021.After such substitution, the Old provisions relating to Reassessment, do not survive. The Central Board of Direct Taxes (C.B.D.T) by way of various notifications had extended the time limit of issuing the notice U/s 148 of the Act up to 30th […]
Four level of approvals are required before issuance of notice from specified authority . 1. Before conducting enquiry u/s 148A(a) 2. Before issuing notice under section 148A(b) 3. Before passing order under section 148A(d) 4. Before issuing notice under section 148 [proviso to section 148] In case where procedure under section 148A is not applicable […]
Under the new previsions, before issuing notice, AO is required to comply with procedure under Section 148A. Earlier to 1.4.2021 before issue of notice u/s148 reason recorded by AO was the requirement . Now from 1.4.2021 issue of notice u/s 148A which is an opportunity to the assessee to explain his case when revenue requires […]
Section 147 has been Amended vide Finance Act 2021. Information is required by AO for reopening not “Reasons to believe” If any income chargeable to tax, in the case of an assesses, has escaped assessment for any assessment year. The assessing office may, subject to the provisions of Section 148 to 153, assess or re-assess […]
Honourable Calcutta High Court too stayed the reassessment proceedings under section 148 read with section 148A , notices issued post 31/03/2021 and the notifications of extension of notices , following the ratio of the other HC judgements on similar issues . Interim order of STAY PASSED
Bagaria Properties and Investments Private Limited & Anr. Vs Union of India and Ors. (Calcutta High Court) The Court:-In this matter petitioners have challenged the impugned notices dated 29th May, 2021 and 18th June, 2021 relating to assessment years 2014-15 and 20 15-16 respectively under Section 148 of the Income Tax Act, 1961 on the […]
Mudra Finance Limited Vs ITO (Delhi High Court) Petitions have been heard by way of video conferencing. Present writ petitions have been filed challenging t he notices dated 09th June, 2021, 30th June, 2020 and 28th June, 2020 issued in W.P. (C) 6442/2021, 6443/2021 and 6451/2021 respectively by respondent No.1 under section 148 of the Income Tax […]
Briefly, the issue concerns the applicability of the newly inserted provisions of Section 148A and the amendments brought inter alia in Section 149 of the Act. According to the petitioner, the proceedings should conform to the amended provisions.