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Income Tax : ITAT ruled that the reassessment order passed under Section 147 was unsustainable as it exceeded the limitation period prescribed ...
Income Tax : ITAT Hyderabad held that the reassessment notice issued for AY 2015-16 after 31.03.2022 was barred by limitation under the first p...
Income Tax : The Court held that a Section 148 notice issued beyond the statutory six-year limitation period is invalid. It ruled that expired ...
Income Tax : The issue was whether delay in filing appeal without strong documentary proof should be condoned. The ITAT held that when sufficie...
Income Tax : The Tribunal ruled that admitting additional evidence without seeking a remand report from the Assessing Officer breaches Rule 46A...
Learn the updated provisions governing rectification, assessments, reassessments, and appeals under the Income-tax Act. This guide explains procedures, timelines, appellate remedies, and taxpayer rights after the Finance Act, 2026.
ITAT ruled that the reassessment order passed under Section 147 was unsustainable as it exceeded the limitation period prescribed by the Income-tax Act. The decision highlights that statutory timelines cannot be ignored without supporting evidence from the Revenue.
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 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 delay in filing appeal without strong documentary proof should be condoned. The ITAT held that when sufficient cause exists, delay must be liberally condoned to ensure justice and hearing on merits.
The Tribunal ruled that admitting additional evidence without seeking a remand report from the Assessing Officer breaches Rule 46A. The matter was sent back to the AO for reconsideration after examining the evidence.
The Tribunal ruled that penalty for non-response to notices cannot survive when the assessee later participates in the assessment proceedings. Since the final assessment was not completed ex-parte, the penalty was deleted.
The Tribunal observed that when a foundational jurisdictional issue exists, dismissal on limitation without examining merits is unsustainable. The reassessment and all consequential penalties were accordingly quashed.
Since the reassessment itself was quashed, the addition treating long-term capital gains as unexplained cash credit under section 68 automatically failed. Jurisdictional defects were fatal to the assessment.
The Tribunal found that additions under section 69A were made without examining evidence due to non-compliance. The matter was remanded to allow verification of claimed trading and agricultural receipts.
