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 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 : Court upheld the validity of the Section 148 notice but set aside the assessment order after finding that notices were sent to an ...
Income Tax : Tribunal reiterated that credits brought forward from earlier financial years cannot ordinarily be taxed under Section 68 in subse...
Income Tax : The Delhi High Court held that reassessment proceedings cannot be sustained on changing allegations introduced after issuance of n...
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 tribunal addressed whether delay in filing appeals due to procedural difficulties justified condonation. It held that genuine hardship caused by PAN mismatch and filing issues constituted sufficient cause, allowing the appeal.
The Tribunal held that disallowance of loss based on alleged penny stock manipulation was not justified without corroborative evidence. It found that transactions were supported by demat and banking records.
The issue was whether reassessment beyond 3 years is valid when escaped income is below ₹50 lakh. The ruling held such notice invalid under Section 149, and the key takeaway is strict adherence to limitation rules.
ITAT held that reassessment initiated with approval from the wrong authority is invalid when issued beyond three years. The entire proceedings were quashed. The key takeaway is that proper sanction under Section 151 is mandatory.
The case addressed whether a special audit can be ordered without establishing complexity or defects in accounts. The Court examined whether mechanical invocation of Section 142(2A) without proper justification is legally sustainable.
The Court held that reassessment proceedings are invalid if approval is obtained from an incorrect authority. It clarified that sanction must strictly comply with Section 151 based on elapsed time limits. The ruling reinforces jurisdictional safeguards in reassessment cases.
ITAT held that reassessment notice issued after three years without PCCIT approval violates Section 151(ii). The approval taken from PCIT was found insufficient. The ruling confirms that proper authority approval is mandatory for valid reassessment.
The issue was whether reassessment can proceed without disclosing full allegations to the taxpayer. The Court held that failure to provide an opportunity to respond violates natural justice. The key takeaway is that reassessment notices must clearly communicate all grounds.
The Tribunal validated reopening under Section 147 based on credible post-search information. Proper procedure under Section 148A was followed, making reassessment lawful.
The Tribunal held that a notice issued under section 148 beyond the six-year limitation under the old law is invalid. It clarified that the first proviso to section 149 bars such reopening even under the amended regime.
