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...
Evaluate the reasonableness of Notices issued under section 148 of Income Tax Act, as amended in the Finance Act 2021. Get to know the time limits for issuing a Reassessment Notice.
Appellants to file a representation before assessing officer and explaining as to why two PAN numbers were obtained by appellants / assessee.
Auroglobal Comtrade Private Limited Vs Chairman, CBDT & Others (Orissa High Court) HC declined to accept challenge to the Reopening notices under Section 148-A(1)(b) of the Act as well as the consequential order under Section 148-A(1)(d) of the Act by holding that the Petitioners/Assessees in those cases would have a full opportunity of urging all […]
Punjab and Haryana HC rejects interference at early stage in Anshul Jain Vs PCIT case. The court holds that objections can be raised in re-assessment proceedings.
A perusal of the instruction would show that PAN – AAACK4O32H concerns an entity going by the name K.G. Finvest Pvt. Ltd. This PAN does not concern M/s Kanhaiya Impex Pvt. Ltd. The petitioner’s stand that it had not entered into any transaction with M/s Kanhaiya Impex Pvt. Ltd. is correct. Given this position, in our view, both the notice which is issued under Section 148 A (b) of the Act and the order that was passed under Section 148 A (d) of the Act suffer from obvious errors.
Assessment Order has been passed without considering the objection filed by the petitioner against the notice under Section 148A(b) of the Act and also on the ground that the said order is in violation of principle of natural justice by not affording any opportunity of hearing to the petitioner in spite of specific request.
HC held that it is clear that there is no record to suggest that the procedure contemplated u/s 148A of the Act were followed before issuing notice under Section 148
Delhi High Court in the case of Usha Rani Girdhar v. ITO held that Assessing officer cannot add primary allegation in Notice by issuing Supplementary Notice.
Vidisha Singhal Vs ITO (Delhi High Court) AO admits that the impugned order passed under Section 148A(d) of the Act is riddled with mistakes. He further admits that in the notice issued under Section 148A(b) of the Act, the details of the transactions allegedly carried out by the petitioner were not correct. He states that […]
Mittal International Vs ACIT (Delhi High Court) 1. Present writ petition has been filed challenging the impugned order passed under Section 148A(d) of the Income Tax Act, 1961 (for short ‘Act’) and notice issued under Section 148 of the Act, both dated 26th July, 2022 for the Assessment Year 2016-17. 2. Learned counsel for the […]