Sanction by specified authority not obtained as per amended ...

Impugned notice quashed due to lack of sanction for reopening assessment beyond 3 years, violating Section 151(ii). Notification can't override statute.

Case Laws Income Tax

July 13, 2024

Sanction by specified authority not obtained as per amended provisions of Section 151 for reopening assessment beyond 3 years, rendering impugned notice invalid; notification under TOLA cannot override statutory provisions; impugned notice quashed being contrary to Section 151(ii) requiring sanction from higher authority for reopening beyond 3 years.

View Source

← Previous Next →

Sanction by specified authority not obtained as per amended ...

Impugned notice quashed due to lack of sanction for reopening assessment beyond 3 years, violating Section 151(ii). Notification can't override statute.

Case Laws Income Tax

July 13, 2024

You may also like:

The High Court quashed the reopening notice issued by the Assessing Officer u/s 148 for reassessment beyond the period of four years. The assessee had filed returns...

Reopening of assessment u/s 147 was based on reasons to believe the difference between total cash sales and cash sales reflected in books. Held: Reopening was made only...

Reopening of assessment - applicability of time limitation - Exemption from levy of Entry Tax - The reopening of the assessment for the year prior to 2012-13 is beyond...

Validity of reopening of assessment u/s 147 - by the time, assessment order for the assessment year 2004-05 was passed on 31.12.2010, six year period for reopening of...

Reopening of assessment notice beyond four-year period quashed. Assessee submitted complete details for section 80IA deduction claim with return. No failure to disclose...

Reopening of assessment u/s 147 after 4 years - Validity of Sanction for issue of notice u/s 151 - respectfully following the aforesaid decision provisions of section...

Validity of assessment order - Assessing Officer himself has not considered the assessment year 2008-09 as covered u/s 153C of the Act. The assessing Officer has issued...

Reopening of assessment u/s 147 - The High Court noted that the issue of disallowance under Section 14A of the Act had been thoroughly examined during the original...

Reopening of assessment u/s 147 - period of limitation - The High Court observed that, the three-year time period of A.Y 2016-17 had ended on 31.03.2020. Accordingly,...

Reopening of assessment u/s 147 - Bypassing the option to initiate scrutiny assessment u/s 143(3) - The assessment proceedings would cease to be pending either by...

Reopening of assessment u/s 147 was challenged. The Assessing Officer (AO) had disallowed 20% of total sundry creditors in the regular assessment u/s 143(3). The AO...

Reopening of assessment u/s 147 - reopening after expiry of four years - Original assessment have been passed under section 143(3) on Dated 14.12.2011 and A.O. recorded...

Mere assertion of "failure to disclose fully and truly all material facts" does not confer jurisdiction for reopening assessment beyond four years. AO must demonstrate...

Reopening of assessment u/s 147 - Reopening based on audit objections - reasons to believe - High Court observed that, reopening an assessment beyond four years requires...

Reopening of assessment u/s 147 - reopening beyond the period of four years - Merely because while framing assessment for the subsequent year, the AO noticed certain...

Quick Updates: