S. 148 : Reassessment-Notice-Second notice-After High Court remanded the matter.-Second notice is bad in law. [S. 153(6)(i), Art. 226]
Elite Pharmaceuticals v. ITO [2023] 291 Taxman 597 (Cal)(HC)S. 148 : Reassessment-Notice-Second notice-After High Court remanded the matter.-Second notice is bad in law. [S. 153(6)(i), Art. 226]
Elite Pharmaceuticals v. ITO [2023] 291 Taxman 597 (Cal)(HC)S. 147 : Reassessment-Within four years-Change of opinion-Compensation payable-Based on record that was already with the Assessing Officer at the time of the proceedings-Reassessment notice and order disposing the objection was quashed..[S. 37(1), 143(3), 260A]
PCIT v. NESCO Ltd. (2023) 291 Taxman 286 (Bom)(HC)S. 147 : Reassessment-With in four years-Contribution to certain funds-Not claimed any relief-Reassessment notice and order disposing the objection was quashed.[80CCC(1), 148, Art. 226]
Piyush Ambalal Gandhi.v. DCIT (2023) 457 Itr 411/ 291 Taxman 396 (Guj)(HC)S. 147 : Reassessment-With in four years-Unexplained investment-Laundering of huge funds-Rotation of funds-Reassessment notice and order disposing the objection is justified [S. 69B, 148, Art. 226]
Omni Lens (P.) Ltd. v. ACIT (2023) 291 Taxman 619 (Guj)(HC)S. 147 : Reassessment-After the expiry of four years-Cash credits-Cash deposit in the bank-Information from Bank-Factual error cannot be considered in writ proceedings-Order of single judge was affirmed.[S. 68, 143(1), 148, Art. 226]
Gem Edible Oils (P.) Ltd. v. ACIT (2023) 291 Taxman 242 (Mad)(HC) Editorial : Order of single Judge, Gem Edible Oils (P.) Ltd. v. ACIT (WP No. 10769 of 2022 dt. 27-4 2022)(Mad)(HC).S. 147 : Reassessment-After the expiry of four years-Guarantee commission-Interest on borrowed capital-Disallowance of expenditure-Exempt income-Method of accounting-Income reconciliation as per Form 26AS-No failure to disclose material facts-Reassessment notice and order disposing the objection was quashed.[S. 14A, 36(1)(iii), 37(1), 145, Form. 26AS, Art. 226]
P C Snehal Engineers (P.) Ltd. v. ACIT (2023) 291 Taxman 547 (Guj.)(HC)S. 147 : Reassessment-After the expiry of four years-Transfer-Joint development agreement-Reassessment notice and order disposing the objection was quashed. [S. 2(47)(v), 45(7), 148, Art. 226]
Chhaganlal Mulji Dholu v. JCIT (OSD) (2023) 456 ITR 465/291 Taxman 304/330 CTR 687/ 221 DTR 469 (Guj.)(HC)S. 147: Reassessment-After the expiry of four years-No failure to disclose material facts-Annual accounts certified by the Chartered Accountant/ Auditor wherein a clear reference was made to the fact which was the subject matter of reopening-Notice and order disposing the objection was quashed. [S. 69A, 148, Art. 226]
Tumkur Minerals (P.) Ltd. v. JCIT (2023) 456 ITR 286/ 291 Taxman 340 /330 CTR 177 (Bom)(HC)S. 147 : Reassessment-After the expiry of four years-Business expenditure-Advertisement-Not open for the AO to reopen assessment based on very same material and to take a different view-Order of High Court affirmed. [S. 148, Indian Medical Council Act, 1956 read with Indian Medical Council (Professional Conduct, Etiquette and Ethics) Regulations, 2002, Art. 136]
ITO v. Rich Feel Health & Beauty (P.) Ltd. (2023) 291 Taxman 203 (SC) ITO v. Rich Feel Health & Beauty (P.) Ltd. (2023) 291 Taxman 444 (SC) ITO v. Rich Feel Health & Beauty (P.) Ltd. (2023) 291 Taxman 436 (SC) Editorial: Rich Feel Health & Beauty (P.) Ltd. v. ITO (2022) 440 ITR 41 / 284 Taxman 286 (Bom)(HC), affirmed.S. 147: Reassessment-Notice after the expiry of four years-Revision proceedings was dropped by the PCIT-Sanction given for reassessment on same ground-Non application of mind-SLP of revenue dismissed. [S. 115JB, 143(3) 263 Art. 136]
ACIT v. Godrej and Boyce Manufacturing Co. Ltd. [2023] 453 ITR 14 / 293 Taxman 311 (SC) Editorial: Godrej and Boyce Manufacturing Co. Ltd (2023) 453 ITR 10 (Bom)(HC), is affirmed.