Income Tax : The guide provides detailed rules for VDA transfers executed through exchanges, brokers, and payment gateways. It identifies who i...
Income Tax : ITAT Mumbai quashes reassessment (AY 13-14, 14-15) as AO missed the Rajeev Bansal-mandated "surviving limitation." S. 149 prevails...
Income Tax : Analysis of the Rajeev Bansal Supreme Court ruling on reassessment approvals, clarifying complexities in Section 151 and its impac...
Income Tax : Explore key court rulings on reassessment under Section 148 post-2021 amendments, covering procedural changes, taxpayer rights, an...
Company Law : Overview of Section 149 of the Companies Act, 2013: Board composition, women directors, resident and independent directors' roles,...
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...
Income Tax : The Madras High Court held that delayed transfer of seized documents under Section 132(9A) did not invalidate notices issued under...
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 Tribunal held that reopening beyond three years requires escaped income in the form of an asset. Since bogus purchases are revenue items, the reassessment was declared invalid.
The tribunal held reopening invalid where actual escaped income was below ₹50 lakh. It clarified that jurisdiction depends on real income, not transaction value.
ITAT remanded the matter where the assessee claimed PAN misuse leading to additions under Sections 68 and 69. It directed AO to verify the police report, holding that relief must be granted if misuse is substantiated.
The Tribunal examined whether reassessment proceedings were valid when initiated beyond the statutory time limit. It held that the notice issued under Section 148 was barred by limitation and invalid. The ruling emphasizes strict adherence to limitation provisions in reassessment cases.
ITAT Mumbai held that reassessment initiated without approval from the correct authority under Section 151 is invalid. Since the reassessment itself was void, the revision order under Section 263 could not survive.
The Tribunal held that reopening beyond three years requires sanction from higher authorities under Section 151(ii). Since approval was obtained only from the PCIT, the reassessment notice was declared invalid.
The tribunal noted discrepancies in the dispatch register used to prove issuance of the notice. Because the records did not inspire confidence, the tribunal held the reassessment notice to be time-barred.
The Tribunal held that a notice under section 148 issued beyond three years requires sanction from PCCIT under section 151(ii). Approval from PCIT was held insufficient, leading to quashing of the reassessment.
ITAT held that the reassessment notice issued under Section 148 was valid because the Assessing Officer followed CBDT Instruction 1/2022 and the Supreme Court’s decision on reassessment procedures. The Tribunal rejected the argument that the notice was barred by limitation.
ITAT Delhi held that reassessment proceedings under Section 147 cannot be initiated while scrutiny assessment under Section 143(2) is still pending. Such parallel proceedings are without jurisdiction and render the entire reassessment order invalid.
