As per the amendment brought in by the Finance Act 2023 with effect from 1.4.2023 in Section 148 of the Income tax Act, notice for reassessment is required to be issued by the AO requiring the assessee to furnish within "a period of three months from the end of the month in which such notice is issued or such further period as may be allowed by the Assessing Officer on the basis of an application made in this regard by the assessee". This means that the assessee is to be given not less than 3 months' time to file return in…
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Dear Sir, After Supreme Court judgment of Union of India vs. Ashish Aggarwal 439 ITR 1, assessee received notice u/s 148A(b), assessee filed reply and received order u/s 148A(d) alongwith notice u/s 148 for A.Y. 2013-14 on 22.07.2022. In the notice received u/s 148, four reasons were mentioned but none of them is ticked. As the notice does not specify the cause / reason in the notice, whether notice is valid or not. Copy of the notice is attached. Please clarify. Thanking You, Yours Sincerely, CA S.K. Goyal A.R.
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A Search and Seizure action was carried out on the residence of Mr. X and his Group Company premises. In pursuance of the said search, the Dept has issued notices u/s 148 for A.Y. 2013-14 onwards to various entities. In light of the same, Certain Notices are issued in the name of Y and Co Private Limited' which had merged with Z and Co Limited; Writ Petitions against the same are filed in light of Maruti Sukuzi (SC) and Alok Knit Exports Pvt Ltd (Bom HC). M/s. T Private Limited is also been issued with a similar notice which is…
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Third-party evidence for making a reassessment of whether valid
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Assessee is individual and offered the income U/Sec.44AD for A.Y. 2015-16. The case of selected for limited scrutiny on the ground that large cash deposits in the Bank. Assessee has given the explanation that these are out of cash sales offered in the Gross sales considered for the computing the income U/Sec. 44AD of the Act. After due verification of evidences submitted and explanation given by the assessee, assessement order was passed 22.12.2017 U/Sec 143(3) of the Act. A notice U/Sec. 148A(b) of the Act for A.Y 2015-16 sent as per the directions of The Hon’ble Supreme court on 04.05.2022 …
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Assessee has received Notice for showing causes as to why order for reassessment should not be issued against the assessee dated 22 March 2023 The AO has passed order dated 25 March 2023 The provision read under provides time limit of 30 Days from the end of the month in which reply has been made Does the order passed becomes void-ab-initio as the month of Reply has not ended yet? or the Time limit given only provides an upper limit and not range of dates? Regards,
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Search u/sec. 132 of the Act is carried out in the month of Jan 2023 and incriminating documents are found for the FY 2010-11 to Jan 23 are found. How many years of assessment will be re opened for 6 years or 10 years proceedings the year of search 22- 23.
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this is passed with approval of PCIT, is this final and free from from any other action ?
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The notice us 148 of I.T Act , aswellas , notice u/s 148A(b) of Income tax Act has been issued on 08.04.22 for the first time as the assessee has deposited more than 50 Lakhs in financial year 2014-15 .My Querry is that whether the notice issued is barred by limitation or well with in the time?
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For our assessee notice u/s 148A issued, they came to us after time period for reply is over, officer passed order u/s 148A(d), and assessee not filed original return. what is the next procedure, please let us know. With Regards,
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