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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...
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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 reassessment was based on documents found during a search conducted on another person. The Tribunal held that proceedings should have been initiated under Section 153C and not under Sections 147/148, rendering the reassessment invalid.
ITAT Delhi held that reassessment proceedings beyond the prescribed period were invalid where alleged escaped income arose from unaccounted sales and not from assets. The Tribunal ruled that conditions under Sections 149 and 153A were not satisfied, leading to quashing of multiple reassessment notices.
Telangana High Court held that reassessment notices under Section 148 were time-barred because they were dispatched from the ITBA portal after 31.03.2021. The Court ruled that mere digital signing or generation of notices within limitation was insufficient without actual dispatch.
The Delhi ITAT held that a reassessment notice digitally signed on 31 March 2021 but served on 1 April 2021 falls under the new Section 148A regime. Failure to follow mandatory reassessment procedures rendered the entire assessment void.
ITAT Hyderabad held that the reassessment notice issued for AY 2015-16 after 31.03.2022 was barred by limitation under the first proviso to Section 149 and therefore invalid.
The Delhi High Court held that reassessment proceedings for AY 2013-14 were valid since the limitation period stood extended till 30 June 2021 under TOLA.
The ITAT Chandigarh held that reassessment proceedings initiated under an incorrect and obsolete PAN suffered from a jurisdictional defect. The Tribunal ruled that failure to consider the assessee’s reply under Section 148A invalidated the reassessment proceedings.
Court ruled that reassessment notices under Section 148 must be issued through the faceless mechanism under Section 151A and the 2022 Scheme. Notice issued by the Jurisdictional Assessing Officer was held invalid and quashed.
The Tribunal held that the reassessment notice issued on 26.07.2022 was beyond the permissible timeline under the surviving limitation principle and therefore lacked legal validity.
Mumbai ITAT held that reassessment notice issued under Section 148 for AY 2015-16 on 31.07.2022 was barred by limitation under Section 149. The Tribunal quashed the entire reassessment proceedings and assessment order.