Tag: satisfaction 148
Mere use of expression “Yes, I am satisfied” cannot be considered to be a valid approval u/s 148 – High Court In a recent judgment, the Hon’ble Delhi Court has held that the mere use of expression “Yes, I am satisfied” for issuance of notice under Section 148 …
PCIT approval for re-opening only by putting signing was without application of mind -SC dismissed SLP PCIT approval for re-opening only by signing was without application of mind –Supreme Court dismisses SLP of the Income Tax Department In a recent judgment, Hon’ble Supreme Court has dismissed the …
New allegation added in order passed u/s 148A(d) not present in show cause notice u/s 148A. High Court declines interference. In a recent judgment, Allahabad High Court has declined to entertain a Petition challenging addition of a new allegation in order passed u/s 148A(d) in reassessment proceedings. ABCAUS …
High Court declines interference under writ jurisdiction at conclusion stage of re-assessment proceedings. In a recent order, the Hon’ble Allahabad High Court has declined interference under writ jurisdiction at conclusion stage of re-assessment proceedings. ABCAUS Case Law Citation:ABCAUS 3857 (2024) (02) HC In the instant case, the assessee …
No addition can be made on issues for which case was not reopened. Reassessment quashed as addition made on issues not recorded in reasons. The case of the appellant assessee in this case was when no addition has been made on the issue for which the case was …
Amendments made to provisions of Income escaping assessment and search assessments by Budget 2021-22. Revised time limit for issuing notice Under the existing provisions, the Assessing Officer has reason to believe that any income chargeable to tax has escaped assessment for any assessment year, he may reopen the …
CIT need not to given separate reasons for his satisfaction in giving approval u/s 151 for reopening of assessment if reasons recorded by AO have a direct nexus with the information and formation of belief of income escapement. ABCAUS Case Law CitationABCAUS 3388 (2020) (09) ITAT Important case …
Second reopening notice u/s 148 issued without completing earlier reassessment proceedings is invalid ABACUS Case Law CitationABCAUS 3370 (2020) (08) ITAT Important case law relied upon by the parties:A.S.S.P. & Co. vs. CIT 172 ITR 274 (Mad)CIT vs. P. Krishnankutty Menon, 181 ITR 237 (Ker)Tao Publishing (P) Ltd. …
Non-rejection of explanation in Assessment Order amounts to AO accepting it hence no reopening on change of opinion. SC upholds High Court judgment ABCAUS Case Law Citation:ABCAUS 3322 (2020) (06) SC In a recent judgment, the Hon’ble Supreme Court had dismissed the Special Leave Petition filed by the …
Reopening quashed as AO not recorded reasons of assesse’s failure to disclose material facts fully and truly but notice u/s 148 was issued on change of opinion ABCAUS Case Law Citation:ABCAUS 3236 (2020) (01) ITAT Important case law relied upon by the parties:Sadbhav Engineering Ltd. vs. DCITCIT Vs. …
