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Income Tax : ITAT Mumbai quashes reassessment (AY 13-14, 14-15) as AO missed the Rajeev Bansal-mandated "surviving limitation." S. 149 prevails...
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Income Tax : Discover how Finance Act 2021 revamped assessment and reassessment procedures under Income-tax Act, impacting notices, time limits...
Income Tax : The Tribunal held that the reassessment notice issued on 26.07.2022 was beyond the permissible timeline under the surviving limita...
Income Tax : Mumbai ITAT held that reassessment notice issued under Section 148 for AY 2015-16 on 31.07.2022 was barred by limitation under Sec...
Income Tax : ITAT ruled that appellate powers under Section 251 are confined to assessment year under appeal. Directions to reopen completed as...
Income Tax : The Tribunal ruled that the Revenue must establish a direct connection between seized material and the assessee’s taxable income...
Income Tax : Hyderabad ITAT held that a notice issued under Section 148 after six years from the end of AY 2015-16 was invalid. The Tribunal ru...
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The Tribunal held that the reassessment notice issued on 26.07.2022 was beyond the permissible timeline under the surviving limitation principle and therefore lacked legal validity.
Mumbai ITAT held that reassessment notice issued under Section 148 for AY 2015-16 on 31.07.2022 was barred by limitation under Section 149. The Tribunal quashed the entire reassessment proceedings and assessment order.
ITAT ruled that appellate powers under Section 251 are confined to assessment year under appeal. Directions to reopen completed assessments for another year were held beyond jurisdiction.
The Tribunal ruled that the Revenue must establish a direct connection between seized material and the assessee’s taxable income before invoking Section 153C. Mechanical initiation of proceedings for multiple years was declared invalid.
Hyderabad ITAT held that a notice issued under Section 148 after six years from the end of AY 2015-16 was invalid. The Tribunal ruled that the amended 10-year reopening provision cannot revive already time-barred cases.
The Bombay High Court held that reassessment proceedings issued beyond three years for AY 2018-19 were invalid because approval was granted by the Principal Commissioner instead of the competent authority under Section 151(ii).
The Calcutta High Court restrained the Income Tax Department from taking coercive steps in reassessment proceedings for AY 2015-16. The petitioner argued that the Section 148 notice issued in December 2024 was barred by limitation under the first proviso to Section 149.
ITAT Surat restored reassessment appeals to the CIT(A) after observing that the assessee should receive one final opportunity to present evidence. The Tribunal imposed costs due to partial compliance before the appellate authority.
The Pune ITAT held that reassessment proceedings become void when approval under Section 151 is taken from the wrong authority. Since sanction was obtained from the PCIT instead of the PCCIT, the notice under Section 148 was quashed.
ITAT Bangalore held that Section 45(5A) applies prospectively and cannot govern JDAs executed before 01.04.2018. Capital gains from older development agreements must be taxed under the law applicable in the year of transfer.