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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...
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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 ITAT held that reassessment initiated in July 2022 for AY 2015-16 was barred by limitation. The ruling confirms that expired cases cannot be revived under the post-2021 reassessment framework.
Uttarakhand High Court held that order of the Competent Authority granting sanction or approval or refusing to grant sanction or approval u/s 151 of the Income Tax Act of 1961 is neither a revisable order, nor an appealable order.
The Tribunal ruled that once the original notice itself is jurisdictionally invalid, later compliance with section 148A is irrelevant. Foundational defects cannot be remedied procedurally.
The Tribunal held that profit estimation cannot rest on conjectures or lump-sum allegations. In absence of identified bogus purchases or factual basis, the entire addition was deleted.
The High Court held that reassessment notices issued after excluding periods mandated by Supreme Court rulings were time-barred, rendering subsequent proceedings invalid
ITAT Kolkata held that ownership, transfer, and transaction resulting into profit from business or profession and capital gain in respect of joint development agreement needs more verification. Accordingly, matter remanded back for fresh adjudication.
The Tribunal held that approval by an incompetent authority under Section 151(ii) invalidates a reassessment issued after three years. The notice and consequential order were declared void for lack of jurisdiction.
The tribunal held that reassessment beyond three years is invalid when alleged escaped income is below Rs. 50 lakh. Notices issued contrary to section 149 after the 2021 amendments were quashed for lack of jurisdiction.
The dispute centered on whether a reassessment notice was time-barred and sanctioned by the correct authority. The Tribunal held that the reply period under section 148A must be excluded, bringing the notice within three years and validating the sanction.
The issue was whether a reassessment notice issued after the prescribed time limit was valid. The Tribunal held that notices for the relevant year issued after the cut-off date were barred by limitation, rendering the reassessment void.