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 held that reopening beyond three years requires escaped income in the form of an asset. Since bogus purchases are revenue items, the reassessment was declared invalid.
The department has identified high-risk cases through its Insight Portal for AYs 2022-25. It directs officers to initiate reassessment proceedings based on risk analysis, emphasizing data-driven scrutiny.
The tribunal held reopening invalid where actual escaped income was below ₹50 lakh. It clarified that jurisdiction depends on real income, not transaction value.
The Tribunal held reassessment invalid as no proper sanction under Section 151 was produced. The notice under Section 148 was quashed, making all additions unsustainable.
The Tribunal held that dividend received from identifiable mutual funds through banking channels cannot be treated as unexplained income. It ruled that proper documentation and traceability negate applicability of Section 68.
The Tribunal upheld revision under Section 263 after finding that the Assessing Officer failed to conduct enquiry into excess diesel shortage claimed by the assessee. It held that incomplete enquiry makes the assessment order erroneous and prejudicial to revenue.
ITAT Mumbai held that reassessment initiated without approval from the correct authority under Section 151 is invalid. Since the reassessment itself was void, the revision order under Section 263 could not survive.
The Tribunal held that Section 269SS does not apply when cash is received as part of final sale consideration at the time of property registration. Since no advance was involved, penalty under Section 271D was deleted.
The Tribunal held that a notice under section 148 issued beyond three years requires sanction from PCCIT under section 151(ii). Approval from PCIT was held insufficient, leading to quashing of the reassessment.
The Tribunal ruled that Section 148A(b) requires a minimum of seven days for the assessee to respond. Failure to grant this statutory period renders the notice and subsequent reassessment proceedings illegal.
