Assessee received notice u/s 148A(b) dt. 16.08.2024. He file reply on 24.08.2024 mentioning as under:- Copy of Approval not provided with the notice u/s 148A(b) and order u/s 148A(d) but provided with notice u/s 148 which was issued on 31.08.2024. Asseessee asked for documents on the basis of which the department wants to re opening the case. The department issued notice on the basis of investigation report but no inquiry was conducted by the officer who issued notice u/s 148A(b). The assessee asked for statement of the persons concerned and also cross examination of the person who issued statement but…
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Notice for AY 2010-11 dated 31.03.2017 was sent electronically at 01:02:38 hrs on 01/04/2017 and the one sent by post for which there's no evidence/proof is brought on record as claimed to have been posted on 31/03/2017 was never delivered to the assessee and got returned with a remark "LEFT". Sec. 148 has used the word "to serve" while sec. 149 has used the terminology of "to issue". Whether issue and serve have different connotations as far as income tax law is concerned even though the judgement of the Supreme Court in DDA vs. H C Khurana speaks otherwise. Similarly…
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Assessment of the assessee for A.Y.2017-18 was re-opened u/s 147 of the Act. Notice u/s 148 of the Act was issued on 31.03.2021 for the said A.Y, no compliance were made to the said notice. AO completed to assessment u/sec 147 r.w.s.144 r.w.s 144B by making an addition of the entire cash payment for purchase of immovable property and treating the same as unexplained investments u/s 69 of the Act . The assessee preferred an appeal before CIT(A) against the order passed u/sec 147 r.w.s.144 r.w.s 144B. The assessee again received notice u/sec 148 for A.Y.2017-18 and order u/s 148A…
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Assessee received order u/s 148A(d) for A. Y. 2013-14 and 2014-15 of the Act within the time limit of 30 days from the date of reply given. However, in the said reply, the AO has not considered the detailed objections raised by the the assessee and also not provided all the information and documents relied upon as required by the decision of Hon’ble Court in the case of Ashish Agarwal, tough it is mentioned that same has been provided to the assessee. In the order u/s 148A(d) of the Act, the AO has stated that assessee’s request for copies of…
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Assessee firm has made declaration under IDS for A.Y.2015-16 amounting to Rs. 3.30 cr. and has paid the installment of tax due on 30.11.2016, 30.03.2017 and 30.09.2017 , however due to mistake of CA , there was shortfall of Rs. 1313000/-, which he has paid on 3.10.2017. The assessee thought he had made the compliance of IDS. since the all the mail id of CA was given , assessee was not aware of the shortfall and proceedings completed by the AO U/Sec.147 r.w.s.144 r.w.s 144B on 22.03.22 , where in AO has taxed the entire amount disclosed under IDS amounting…
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Dear Sir, Assessee received notice dated 20.05.2022 u/s 148A(b) in consequence to Hon'ble SC Order dated 04.05.2022. Assessee's case relates to LTCG. The information mentioned in the notice addressed to the assessee is totally wrong 1. name of the company in which assessee did purchase and sell of shares as per AO is wrong. 2. Amount of shares purchased and sold is wrong. 3. Name of broker to whom assessee purchase and sale of shares is wrong. Assessee filed reply in response to notice u/s 148A(b) mentioning that information given by you is wrong. Now, the assessee approached the concerned…
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Assessee received order u/s 148A(d) of the Act within the time limit of 30 days from the date of reply given. However, in the said reply, the AO has not considered the detailed objections raised by the the assessee and also not provided all the information and documents relied upon as required by the decision of Hon'ble Court in the case of Ashish Agarwal, tough it is mentioned that same has been provided to the assessee. In the order u/s 148A(d) of the Act, the AO has stated that assessee's request for copies of documents, statements and opportunity of cross…
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I received 148 notice for AY2014-15 on 30/06/21 which I challenged in high court. After SC verdict I received reasons to believe, 151 approval and other documents. I found out that both 148 & 151 were digitally signed and time stamped. The time on 151 was later than 148. So practically AO Didn’t have approval from PCIT when he issued 148. I challenged this aspect in my reply to AO. The orders from AO are yet awaited. The last date mentioned on AO Letter for me to submit reply was 9th June. Till date AO hasn’t issued orders or 148.…
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ASSESSMENT FOR A.Y.2014-15 WAS REOPENDED U/S 148 DUE TO AUDIT OBJECTION. FALLOWED BY REOPENING AO ON VERIFICATION OF ASSESSEE COMPANIES RECORDS SATIFYED REVENUE AUDIT WITH NECESSARY DETAILS, FALLOWED BY THIS REVENUE AUDIT DROPPED REOPENING OF ASSESSMENT. AO UPLOADED DROPPING OF REOPENING ORDER ON NFAC PORTAL IN THE MEAN TINE NFAC ISSUED 142(1) NOTICE AND ULTIMATELY COMPLETED ASSESSMENT BY RAISING HUGE DEMAND WITHOUT TAKING COGNIZENCE AO'S ORDER OF AUDIT OBJECTION
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Assessee is proprietor engaged in the business as Gas Agency under Bharat Gas. He has received notice U/sec. 148 for AY. 2013-14 and 2014-15 after 31.03.2021. Assessee filed the Return of Income for both the years and asked for reasons for reopening and copy of proposal sent for approval before higher authorities and approval granted and also.documents as well as information in possession of AO. AO has provided the issues in reason that assessee has deposited huge cash in Bank account . Assessee has once again asked for verbatim copy of reasons , copy of proposal sent for approval before…
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A.Y 2018-19 reopening of case