Income Tax : The guide provides detailed rules for VDA transfers executed through exchanges, brokers, and payment gateways. It identifies who i...
Income Tax : ITAT Mumbai quashes reassessment (AY 13-14, 14-15) as AO missed the Rajeev Bansal-mandated "surviving limitation." S. 149 prevails...
Income Tax : Analysis of the Rajeev Bansal Supreme Court ruling on reassessment approvals, clarifying complexities in Section 151 and its impac...
Income Tax : Explore key court rulings on reassessment under Section 148 post-2021 amendments, covering procedural changes, taxpayer rights, an...
Company Law : Overview of Section 149 of the Companies Act, 2013: Board composition, women directors, resident and independent directors' roles,...
Income Tax : Learn about the new block assessment provisions for cases involving searches under section 132 and requisitions under section 132A...
Income Tax : Discover how Finance Act 2021 revamped assessment and reassessment procedures under Income-tax Act, impacting notices, time limits...
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...
Income Tax : Receipts earned by a German resident individual from rendering managerial, consultancy and business development services outside I...
Income Tax : The Madras High Court held that delayed transfer of seized documents under Section 132(9A) did not invalidate notices issued under...
Income Tax : The Tribunal ruled that an Investigation Wing report alone cannot justify an addition under Section 68 without independent verific...
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...
The issue concerned reopening based on notices never validly served on the assessee. The Tribunal held that defective service of notices strikes at the root of jurisdiction and invalidates the reassessment.
ITAT Hyderabad held that limitation for issuing notice under section 148 of the Income Tax Act would be only 3 years from the end of the assessment year since material suggesting escapement is less than Rs. 50 Lakhs. Hence, notice issued u/s. 148 is beyond period of limitation of three years hence quashed.
The Tribunal held that where reassessment is based solely on search material found during a third-party search, proceedings must be initiated under section 153C. Reopening under section 147 was held to be without jurisdiction and quashed.
Reassessment was struck down as no satisfaction note by the searched person’s AO was shown. The ruling reiterates that limitation cannot be bypassed through procedural shortcuts.
The issue was whether a Section 148 notice for AY 2015-16 issued in August 2024 was time-barred. The Court held it exceeded the ten-year limit and quashed the proceedings.
The issue was whether reassessment notices issued after the extended period under TOLA were valid. The Tribunal held that post–Rajeev Bansal, notices beyond the surviving limitation are time-barred and void.
The case examined whether procedural compliance under section 148A could revive a time-barred reopening. It was held that procedural steps cannot resurrect jurisdiction lost by efflux of time.
The Tribunal ruled that reopening beyond six years is invalid without a recorded satisfaction of undisclosed assets exceeding ₹50 lakh. The takeaway is strict compliance with the fourth proviso to section 153A is mandatory.
The court held that reopening an assessment on the same facts amounts to an impermissible change of opinion. Arbitrary second reassessment notices were quashed with ₹1 lakh costs imposed to deter harassment.
The tribunal ruled that reassessment notices for AY 2015-16 issued after 31 March 2022 are barred by limitation. The key takeaway is that TOLA extensions do not apply to this assessment year.
