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 Madras High Court held that reassessment notices required to be issued by the Faceless Assessing Officer are invalid if issued...
Income Tax : The Madras High Court held that reassessment notices required to be issued by the Faceless Assessing Officer are invalid if issued...
Income Tax : The Jharkhand High Court held that retrospective insertion of Section 147A removed the jurisdictional challenge against reassessme...
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 : 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 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.
Budget 2026 introduces sweeping retrospective amendments affecting limitation, reassessment jurisdiction, DIN validity, and TPO timelines. The changes directly impact ongoing appeals, rectification, revision, and reassessment proceedings, altering litigation strategy for taxpayers and authorities alike.
The Tribunal quashed the reassessment as the notice issued beyond three years failed to satisfy mandatory conditions under Section 149(1)(b). It held that absence of proper jurisdictional facts and compliance rendered the reopening invalid.
The Court granted interim relief after noting absence of proof that mandatory approval under Section 151 was served on the assessee. It held that the petitioner had made out an arguable case warranting stay of the Section 148 notice.
The Tribunal held reassessment invalid as approval was taken from Pr. CIT instead of Pr. CCIT under Section 151(ii). Jurisdictional non-compliance rendered the notice void.
The Tribunal held that the reassessment notice was time-barred under the Supreme Court ruling on surviving period. Notices issued beyond the permissible limit were declared invalid.
ITAT Mumbai quashed reassessment beyond 3 years as escaped income was ₹37.76 lakh (<₹50 lakh) and approval u/s 151 was wrongly granted by PCIT, rendering notice u/s 148 void.
The Tribunal ruled that reopening beyond three years requires approval from higher specified authorities under Section 151. Since approval was taken from an incorrect authority, the reassessment was declared void.
