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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 : 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...
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...
CESTAT Delhi held that since amendment u/s. 134 of the Finance Act, 2023 has not come into force, the present anti-dumping appeal would be maintainable before the Tribunal u/s. 9C of the Customs Tariff Act.
ITAT Mumbai quashes reassessment (AY 13-14, 14-15) as AO missed the Rajeev Bansal-mandated “surviving limitation.” S. 149 prevails over S. 148A procedural timelines.
Relying on the jurisdictional High Court precedent, the Tribunal quashed the entire crore addition, holding that service of the notice beyond the statutory limitation date is a fatal flaw. The decision emphasizes that procedural compliance with the time limit is mandatory and cannot be waived.
The ITAT Chennai upheld the quashing of a reassessment for AY 2017-18, ruling the u/s 148 notice invalid. As more than three years had elapsed, u/s 151(ii) required sanction from the Principal Chief Commissioner (Pr.CCIT), not the Principal Commissioner (Pr.CIT), confirming the jurisdictional defect.
The ITAT Ahmedabad, applying the Supreme Court’s Rajeev Bansal ruling and Gujarat High Court’s precedent, invalidated a reassessment for AY 2017-18. The order u/s 148A(d) and fresh u/s 148 notice, stemming from a deemed notice issued on 30.06.2021, were held time-barred as they were issued 20 days beyond the maximum seven-day ‘surviving time’ limit.
The ITAT Ahmedabad annulled reassessment proceedings as the notice under Section 148 was issued beyond the surviving limitation period prescribed under TOLA and clarified in Rajeev Bansal (SC).
This decision strengthens the protection against time-barred reassessment, emphasizing that the extended limitation under Section 149(1)(b) applies only if the escaped income is factually above ₹50 lakh. The ITAT confirmed the reassessment was invalid as the AO’s final order confirmed the escaped income was much lower than the extended limit required for reopening
ITAT Mumbai held that reassessment notice under section 148 of the Income Tax Act beyond time limit of six year is barred by limitation and hence liable to be quashed. Accordingly, appeal allowed and notice quashed.
The ITAT Delhi invalidated the reassessment proceedings against Huawei International, a Singapore resident, for AY 2014-15. The Tribunal ruled that the AO’s attempt to investigate offshore software receipts, based merely.
The Karnataka High Court ruled that when reassessment is based solely on material seized from a third-party search, the Income Tax Department must follow the specific procedure under Section 153C of the IT Act, not the general Section 147.
