Income Tax : Budget 2026 proposes allowing taxpayers to file an updated return even after receiving a reassessment notice under Section 148. Wh...
Income Tax : Misreporting under Section 270A(9) applies only to six specific circumstances. Where the assessment order does not clearly establi...
Income Tax : The law now proposes a single consolidated assessment-cum-penalty order for under-reporting of income, reducing multiple proceedin...
Income Tax : Detailed overview of penalties under various sections of the Income Tax Act, covering defaults in tax payment, reporting, document...
Income Tax : Section 270A penalties must specify the exact misreporting clause. Vague notices invalidate penalties and can restore immunity und...
Income Tax : Explore amendments to section 253 of Income-tax Act, adjusting time limits for filing appeals to the Income Tax Appellate Tribunal...
Income Tax : The Tribunal held that immunity under Section 270AA cannot be denied due to technical issues in filing Form 68. The penalty under ...
Income Tax : The court ruled that submitting revised returns showing higher income after a search does not wipe out earlier concealment. Crimin...
Income Tax : The Tribunal found that the taxpayer had filed Form 68 seeking immunity from penalty but the request was rejected without due proc...
Income Tax : The tribunal ruled that reallocating management expenses to the profit and loss account under IRDA regulations does not violate la...
Income Tax : Bain & Company Vs D/ACIT (ITAT Delhi) The appeal before the Income Tax Appellate Tribunal (ITAT), Delhi arose from a final as...
The Tribunal held that immunity under Section 270AA cannot be denied due to technical issues in filing Form 68. The penalty under Section 270A was set aside and the matter was remanded for reconsideration.
The court ruled that submitting revised returns showing higher income after a search does not wipe out earlier concealment. Criminal proceedings for wilful tax evasion and false statements remain maintainable.
The Tribunal found that the taxpayer had filed Form 68 seeking immunity from penalty but the request was rejected without due process. It directed the Assessing Officer to re-examine the immunity claim in accordance with law.
Budget 2026 proposes allowing taxpayers to file an updated return even after receiving a reassessment notice under Section 148. While this creates a compliance window to settle disputes, it also imposes an additional 10% levy on tax and interest to encourage faster resolution.
The tribunal ruled that reallocating management expenses to the profit and loss account under IRDA regulations does not violate law and therefore cannot justify disallowance under the Income-tax Act.
Bain & Company Vs D/ACIT (ITAT Delhi) The appeal before the Income Tax Appellate Tribunal (ITAT), Delhi arose from a final assessment order dated 18 December 2024 passed by the Deputy/Assistant Commissioner of Income Tax (International Tax), Gurgaon under Section 143(3) read with Section 144C(13) of the Income-tax Act, 1961. The assessee is a foreign company […]
Misreporting under Section 270A(9) applies only to six specific circumstances. Where the assessment order does not clearly establish that the case falls within those clauses, the enhanced 200% penalty becomes legally vulnerable.
The Court granted ad-interim relief, holding prima facie that no under-reporting arose where deduction was claimed based on a binding High Court judgment later overruled. Coercive recovery was stayed.
The Tribunal held that immunity from penalty requires strict compliance with statutory conditions, and absence of proof of Form 68 filing disentitles relief.
Orissa High Court held that post search operation all pending assessments/reassessments doesn’t not automatically get abated as provisions of section 158BA(2) of the Income Tax Act. Matter must specifically fall within Block Assessment Scheme for abatement. However, writ dismissed as power under Article 226 not invoked.
