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...
ITAT Bangalore held that reassessment proceedings were invalid where approval under Section 151 was granted mechanically. The sanction was based on the incorrect assumption that the assessee had not filed a return.
ITAT held that the appellate authority wrongly dismissed the appeal under Section 249(4)(b) as there was no advance tax liability under Section 209. The matter was remanded for fresh adjudication on merits.
Judicial rulings clarify that satisfaction for initiating action against other persons in search cases must be recorded promptly. Inordinate delay in recording the satisfaction note can lead to the proceedings being quashed as time-barred.
ITAT held that the reassessment notice issued under Section 148 was valid because the Assessing Officer followed CBDT Instruction 1/2022 and the Supreme Court’s decision on reassessment procedures. The Tribunal rejected the argument that the notice was barred by limitation.
The Bombay High Court held that the reassessment notice under Section 148 was issued after the surviving limitation period expired. As a result, the entire reassessment proceedings and assessment order were quashed.
The Bombay High Court ruled that limitation under Section 201(3) must be calculated based on the financial year in which each quarterly TDS statement is filed. The decision confirms that annual or cumulative computation of limitation is not permitted.
ITAT Hyderabad held that reassessment proceedings were invalid because the notice under Section 148 was issued by the jurisdictional officer rather than through the mandatory faceless system. The assessment order was quashed for lack of jurisdiction.
The High Court held that reassessment proceedings for AY 2013-14 were time-barred after computing the surviving limitation as clarified by the Supreme Court. The notice issued beyond the remaining limitation period was quashed.
ITAT Indore held that stamp duty valuation cannot be adopted without considering Section 50C(2)/(3). The matter was remanded for DVO reference and fresh computation.
The High Court held that only 30 days of limitation survived after applying TOLA and Supreme Court rulings. Notices issued after expiry of the surviving period were declared time-barred.
