S. 148A : Reassessment-Conducting inquiry, providing opportunity before issue of notice-Charitable or religious trust-Registration procedure-Alternative remedy-Writ petition is dismissed. [S. 12AA, 148A(b), 148A(d),164, 246A, Art. 226]
S. 148A : Reassessment-Conducting inquiry, providing opportunity before issue of notice-Charitable or religious trust-Registration procedure-Alternative remedy-Writ petition is dismissed. [S. 12AA, 148A(b), 148A(d),164, 246A, Art. 226]
S. 148A : Reassessment-Conducting inquiry, providing opportunity before issue of notice-Limitation-Notice issued after six years-Limitation period expired on 31-3 2020-Limitation for reopening assessment for assessment year 2013-14 expired on 31-3-2020, notice issued in June 2021 in case of assessee was barred by limitation, hence, section 148 notice dated 28-7-2022 issued pursuant to UOI v. Ashish Agarwal(2022) 286 Taxman 183/ 444 ITR 1 (SC) is quashed and set aside as it was invalid, without jurisdiction and barred by limitation [S. 148, 148A(b),148A(d), 149, Taxation and Other Laws (Relaxation and Amendment of Certain Provisions) Act, 2020, S.3, Art. 226]
S. 148A : Reassessment-Conducting inquiry, providing opportunity before issue of notice-Notices issued u/s 148 on or after 1-4-2021 relating to assessment years 2013-14 and 2014-15-Time limit-Finance Act, 2021 which came in to effect from 1-4-2021-TOLA applied to pre-amended law as applicable till 31-3-2021-Notices and all subsequent proceedings are quashed-Interpretation of taxing statutes-Legislative intent.[S. 147, 148, Art. 226]
S. 148 : Reassessment-Notice-Limitation-Factual finding-Dispatch date-High Court dismissed on the ground that no substantial question of law-SLP is dismissed. [S. 147, Art.136]
S. 148 : Reassessment-Notice-Limitation-Factual finding-Dispatch date-No substantial question of law.[S. 147, 260A]
S.147: Reassessment-Best judgment assessment-Order passed in the name of legal heir without granting an opportunity of person hearing-Order is not valid.[S. 144, 148, Art.226]
S. 147: Reassessment-Within four years-Cash credit-Share premium-No tangible material-Reassessment is bad in law.[S.2(24)(xvi), 56(2)(viib), 68, 143(1), Art. 226]
S. 147: Reassessment-With in four years-Shah commission report-No tangible material-Reassessment is quashed. [S. 143(1), 148]
S. 147 : Reassessment-Faceless Assessment-Principle of natural justice-Reasons not provided-Reassessment is not valid-Respondent may proceed in accordance with law. [S.14B, 148, Art. 226]
S. 147 : Reassessment-Long term capital gains-Penny stocks-Reassessment notice is valid-Sanction of specified authority-Not raised earlier-Plea is not entertained-Reasons and satisfaction note is not furnished to the assessee-Directed to dispose the objection by passing a speaking order. [S. 10(38), 45, 148, 151, Art. 226]