Income Tax : The Income Tax Act, 2025 replaces old reassessment provisions with Sections 279 to 286 and increases reopening timelines in certai...
Income Tax : Explains how routine approvals under Section 151 can nullify reassessment proceedings. The key takeaway is that lack of applicatio...
Income Tax : The ITAT held that reassessment cannot run parallel to ongoing scrutiny proceedings. Such action was declared without jurisdiction...
Income Tax : The High Court held that reassessment proceedings for AY 2013-14 were time-barred after computing the surviving limitation as clar...
Income Tax : A detailed look at how the Finance Act, 2021 reshaped Sections 147–151, introduced Section 148A, and reduced limitation periods ...
Income Tax : Discover how Finance Act 2021 revamped assessment and reassessment procedures under Income-tax Act, impacting notices, time limits...
Income Tax : Humble Representation for modification of Section 151 of the Income Tax Act relating to Sanction for issue of Notice under sec. 14...
Income Tax : Income Tax Gazetted Officers’ Association requested CBDT to issue Clarification in respect of the judgement of Hon’ble Supreme...
Income Tax : In view of Indiscriminate notices by income Tax Department without allowing reasonable time it is requested to Finance Ministry an...
Income Tax : Lucknow CA Tax Practicioners Association has made a Representation to FM for Extension of Time Limit for Assessment cases time bar...
Income Tax : SC dismissed Revenue’s plea after Gujarat HC held that even proposed additions would not alter MAT liability, defeating escapeme...
Income Tax : The Court held that although notices were sent to the address available in PAN and passport records, the reassessment order could ...
Income Tax : The Supreme Court declined to examine the Revenue’s challenge after noting that an intra-court appeal remedy existed under the K...
Income Tax : ITAT Chennai held that reopening an assessment after four years based on issues already examined during scrutiny amounted to an im...
Income Tax : The ITAT held that reassessment cannot be sustained when additions are ultimately made on issues not mentioned in the recorded rea...
Income Tax : The department has identified high-risk cases through its Insight Portal for AYs 2022-25. It directs officers to initiate reassess...
Income Tax : Supreme Court in the matter of Shri Ashish Agarwal, several representations were received asking for time-barring date of such cas...
Corporate Law : Income Tax Gazetted Officers’ Association (W.B.) Unit Date: 02.02.2023. To The Principal Chief Commissioner of Income Tax, W...
Income Tax : CBDT directed that cases reopened u/s 147/148A in consonance with Judgement of SC in case of UoI vs. Ashish Agarwal & CBDT instruc...
Income Tax : Consequent to order passed by Allahabad High Court passing severe strictures and proposing to levy exemplary cost of Rs 50 lakhs i...
SC dismissed Revenue’s plea after Gujarat HC held that even proposed additions would not alter MAT liability, defeating escapement claims. HC found all material facts were disclosed during scrutiny assessment; SC left the order undisturbed.
The Court held that although notices were sent to the address available in PAN and passport records, the reassessment order could not stand because the assessee was not given an effective opportunity of hearing. The assessment, demand notices, penalties, and recovery proceedings were set aside.
The Supreme Court declined to examine the Revenue’s challenge after noting that an intra-court appeal remedy existed under the Karnataka High Court Act. The merits of the assessment dispute were left open.
ITAT Chennai held that reopening an assessment after four years based on issues already examined during scrutiny amounted to an impermissible change of opinion. The key takeaway is that reassessment cannot be used as a tool to review a concluded assessment without fresh tangible material.
The ITAT held that reassessment cannot be sustained when additions are ultimately made on issues not mentioned in the recorded reasons for reopening. The AO’s jurisdiction failed because no valid addition survived on the original escapement issue.
The Tribunal found that the Assessing Officer ignored the statutory threshold for reopening assessments beyond three years. The ruling emphasizes that reassessment notices issued contrary to limitation provisions are void in law.
ITAT Chandigarh held that reassessment proceedings were invalid because the Assessing Officer relied on factually incorrect assumptions regarding the filing of return and property purchase. The reopening was therefore quashed as unsustainable in law.
ITAT Chandigarh held that reassessment proceedings were invalid because the Assessing Officer recorded incorrect facts regarding the return filing date and declared income. The Tribunal ruled that such defective reasons could not support a valid belief of escaped income.
The Court held that a Section 148 notice issued on 31.03.2024 for AY 2013-14 exceeded the statutory ten-year limitation period. The reassessment notice was therefore quashed as time-barred.
The Mumbai ITAT held that reassessment initiated beyond three years was invalid because the alleged escaped income was only ₹5 lakh, far below the ₹50 lakh requirement under Section 149(1)(b). As a result, the reassessment and consequential assessment order were quashed.
