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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 : Gujarat HC quashed Section 148 reassessment as it was issued beyond Section 149 limitation, holding Section 152(3) applies to sear...
Income Tax : ITAT Mumbai quashed a Section 148 notice issued after the limitation under the first proviso to Section 149, holding the reassessm...
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Custom Duty : Learn how to file and process Bill of Entry amendments at Jawahar Lal Nehru Custom House. Get insights on self-approval and office...
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 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.
The Delhi High Court held that issuance of notice within limitation is sufficient, and an inadvertent attachment of another assessee’s document is a curable defect, not a jurisdictional flaw.
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 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 ruled that mere reference to high-value transactions cannot justify reopening beyond three years. Absence of statutory conditions under Section 149(1)(b) rendered the reassessment void.
The Tribunal held that the reassessment notice issued after the extended limitation period was invalid under Section 149. As a result, the entire reassessment based on alleged accommodation entries was quashed as void ab initio.
ITAT Bangalore quashed reassessment for AY 2017-18, holding notice issued on 12-04-2024 time-barred under first proviso to Sec.149(1), despite prior 148A proceedings.
The Court ruled that reopening based solely on an audit objection amounts to change of opinion if the issue was previously examined. Without fresh tangible material, reassessment proceedings are unsustainable.