Income Tax : Learn the updated provisions governing rectification, assessments, reassessments, and appeals under the Income-tax Act. This guide...
Income Tax : The article explains how the Finance Acts, 2025 and 2026 have reshaped the Updated Return regime under Section 139(8A). It highlig...
Income Tax : Learn how different types of income tax assessments are conducted under the Income-tax Act. The FAQs explain assessment procedures...
Income Tax : This article explains why reassessment proceedings may be invalid if the Assessing Officer merely relies on Investigation Wing rep...
Income Tax : A detailed overview of limitation periods prescribed under the Income-tax Act reveals how missing statutory deadlines can lead to ...
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 : Madras HC held that merely issuing a corrigendum acknowledging the return did not rectify the defective assessment process and ord...
Income Tax : ITAT held reassessment under Sections 147/148 invalid because it was based on a pre-1 April 2021 third-party search, requiring pro...
Income Tax : ITAT Mumbai quashed a Section 148 notice issued after the limitation under the first proviso to Section 149, holding the reassessm...
Income Tax : Gujarat HC quashed the reassessment proceedings after holding that ignoring the assessee's adjournment request violated natural ju...
Income Tax : ITAT Kolkata held that extensive documentary evidence, audited books, supplier confirmations and banking records established the g...
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...
The ITAT restored the ₹1.11 Cr capital gains addition for the sale of alleged agricultural land back to the AO for fresh verification. The matter was sent back due to the assessee’s non-compliance and non-submission of evidence in prior proceedings.
Bombay High Court held that reassessment for AY 2016–17 was invalid as the sanction was not obtained from the competent authority mandated under Section 151(ii) of the Income-tax Act.
ITAT Pune allowed the appeal, holding that the AO lacked jurisdiction because the necessary approval for the Section 148 notice, issued for A.Y. 2017-18 after three years, was obtained from the wrong authority. Following jurisdictional precedents, the Tribunal confirmed that the invalid approval under Section 151 vitiates the entire reassessment process.
The ITAT Delhi quashed reassessment orders for three assessment years (AY 2011-12, 2015-16, 2016-17) based on fundamental legal flaws. The ruling confirms that reassessments are invalid if initiated on wrong or substituted reasons, if they are time-barred (following the Supreme Court’s concession in the Rajeev Bansal case), or if they proceed without valid statutory sanction from the competent authority.
The ITAT Delhi upheld the deletion of a Rs.1.83 crore addition for alleged bogus loans, ruling that uncorroborated WhatsApp chats and retracted search statements cannot override documentary evidence. The Tribunal affirmed the loans were genuine, noting the assessee provided full proof of identity, creditworthiness, and genuineness via audited accounts, bank statements, and TDS on interest paid to the NBFC lenders.
ITAT Kolkata quashed the reopening assessment for AY 2015-16, ruling the Section 148 notice issued on 31.07.2022 was time-barred. This decision strictly follows the Rajeev Bansal (SC) judgment, which held that the TOLA extension for reopening notices did not apply to AY 2015-16 beyond 31.03.2021.
ITAT Delhi nullified a reassessment, ruling that mandatory sanction under Section 151 was invalid because it was granted by Principal Commissioner (PCIT). Tribunal held that reopening assessments after three years requires approval from higher authority: Principal Chief Commissioner (PCCIT).
The Court held that the entire series of reassessment actions, including the final assessment and penalty notices, were bad in law because the initiating notices were issued by the wrong authority, violating Section 151A. This quashing emphasizes the mandatory nature of the faceless assessment protocol, unless the Supreme Court later validates the department’s action.
Judicial precedent from Karnataka HC confirms that Assessing Officer must provide not less than seven days to an assessee to respond to a show-cause notice under Section 148A(b). Failure to comply renders the notice and all subsequent reassessment steps, including the order and penalty notice, invalid.
The ITAT Pune quashed reassessment proceedings, ruling them void ab initio because the requisite approval under Section 151(ii) was granted by the Principal Commissioner of Income Tax (PCIT) instead of the Principal Chief Commissioner (PCCIT). This failure to follow the mandatory jurisdictional hierarchy for notices issued after three years vitiated the entire reopening.
