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Delhi High Court held that where notice is sent electronically, the date of dispatch of e-mail is to be considered as date of issue of notice and date of digital signature is irrelevant. Accordingly, petition dismissed.
ITAT Jaipur dismisses appeals by Chandalal Verma, confirming income additions for AY 2011-12 and 2017-18, citing Section 292C presumption on seized documents.
Karnataka High Court held that assumption of jurisdiction under section 147 of the Income Tax Act untenable since mandatory requirement of section 149(1)(b) of the Income Tax Act not complied. Accordingly, writ petition allowed and notice u/s. 148 quashed.
Bombay High Court held that notice issued under section 148 of the Income Tax Act beyond the time period specified under section 149(1) of the Income Tax Act is non-complaint and invalid. Accordingly, order passed thereon is liable to be quashed.
ITAT Jaipur held that reopening under section 148 r.w.s. 148A is bad-in-law and liable to be quashed in as much as reopening was merely on the basis of change of opinion. Accordingly, appeal of assessee allowed and reopening quashed.
Delhi High Court sets aside a Section 148 income tax reassessment notice for Assessment Year 2015-16, ruling it time-barred based on the Revenue’s concession in a Supreme Court case.
Assessee challenged this, arguing the procedure under Section 148A was not followed. The Supreme Court ruled that notices after 31.03.2021 had to follow the amended Section 148A.
Patna High Court held that notice must be supported by reasons. Accordingly, since notice issued under section 148 of the Income Tax Act is not supported by reasons the same is liable to be quashed. Thus, writ petition stand allowed.
Held that the AO seeks to disallow expenses on account of doubting the genuineness for the reason that the same were not incurred wholly or exclusively for the purpose of the petitioner’s business.
Delhi High Court held that initiation of reassessment proceedings by issuance of notice under section 148 of the Income Tax Act is not sustainable in law in as much as the same is barred by limitation as stipulated u/s. 149 (1) of the Income Tax Act.