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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 : 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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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 issue was validity of reopening beyond the limitation period. The Tribunal held the notice issued after the prescribed time was invalid, and quashed the entire reassessment.
The issue was whether reassessment beyond 3 years is valid when escaped income is below ₹50 lakh. The ruling held such notice invalid under Section 149, and the key takeaway is strict adherence to limitation rules.
ITAT held that reassessment initiated with approval from the wrong authority is invalid when issued beyond three years. The entire proceedings were quashed. The key takeaway is that proper sanction under Section 151 is mandatory.
The Court ruled that the reassessment notice was invalid as it exceeded the statutory 10-year limit under Section 153A. It clarified that the search year must be included in computing the extended limitation period.
ITAT held reassessment invalid due to approval taken from an incorrect authority under Section 151. The ruling confirms that improper sanction makes the entire proceeding void ab initio.
Zee Entertainment Enterprises Limited Vs DCIT (ITAT Mumbai) The matter concerns two appeals filed by the assessee against orders of the Commissioner of Income Tax (Appeals)-48, Mumbai, for Assessment Years (AY) 2015–16 and 2019–20. Both appeals arise from assessment orders passed under Section 143(3) read with Section 147 of the Income Tax Act, 1961. Since […]
The Court held that a Section 148 notice issued beyond the statutory six-year limitation period is invalid. It ruled that expired limitation cannot be revived through later amendments, rendering the reassessment void.
The issue was whether reassessment under Section 147 is valid after a search. The ITAT held it invalid, ruling that only Section 153A applies post-search, making the reassessment void.
With the reassessment proceedings held invalid, additions relating to property valuation and unexplained investment were not examined on merits. The appeal was allowed on legal grounds.
The Tribunal held that a notice issued under section 148 beyond the six-year limitation under the old law is invalid. It clarified that the first proviso to section 149 bars such reopening even under the amended regime.