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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 : Explore key court rulings on reassessment under Section 148 post-2021 amendments, covering procedural changes, taxpayer rights, an...
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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...
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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 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.
ITAT Delhi quashes reassessment (AY 2016-17) and deletes Rs.2.25 Cr LTCG addition after finding that PCIT, not PCCIT, gave the required Section 151 approval.
Assessee did not comply with subsequent statutory notices, leading to an ex-parte assessment order under section 144, where the entire cash deposit was added back to its income under section 69A.
ITAT Hyderabad rules Excel sheets from an accountant’s laptop aren’t ‘books’ or ‘assets,’ quashing reassessment notices against Exel Rubber for mechanical sanction and insufficient evidence.
