Procedural Defect In Section 143(2) Notice Format Is Cured Under Section 292B Validating Assessment

By | July 25, 2026
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Procedural Defect In Section 143(2) Notice Format Is Cured Under Section 292B Validating Assessment Issue Curing Format Non-Conformity Under Section 292B: Whether non-conformity of a Section 143(2) notice with the format prescribed in CBDT Instruction dated 23-06-2017 (such as omitting the classification of scrutiny) invalidates the notice and vitiates the assessment, or whether it constitutes… Read More »

Section 292A Expressly Bars Granting Probation To Adult Offenders Convicted Under Income Tax Act

By | July 25, 2026
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Section 292A Expressly Bars Granting Probation To Adult Offenders Convicted Under Income Tax Act Issue Bar on Probation under Income Tax Act: Whether a trial court can release an adult offender convicted under Section 277 on probation under the Probation of Offenders Act, 1958 or Section 360 of Cr.P.C., given the express statutory bar in… Read More »

Section 277 Conviction Upheld As Taxpayer Failed To Rebut Presumption For Submitting Forged Documents

By | July 25, 2026
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Section 277 Conviction Upheld As Taxpayer Failed To Rebut Presumption For Submitting Forged Documents Issue Validity of Conviction for False Statement in Verification under Section 277: Whether the conviction and sentence under Section 277 (read with Section 278E) are sustainable when an employee-assessee claims a fraudulent tax refund using a forged TDS certificate and a… Read More »

Section 270A Penalty Cannot Survive Quashed Quantum Assessments Or Additions Sustained On Estimated Basis

By | July 25, 2026
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Section 270A Penalty Cannot Survive Quashed Quantum Assessments Or Additions Sustained On Estimated Basis Issue Survival of Section 270A Penalty upon Quashing of Quantum Assessment: Whether a penalty levied under Section 270A for under-reporting of income can be sustained when the underlying quantum assessment order itself is quashed on legal grounds by the Tribunal. Levy… Read More »

Inadvertent Claim Of Full Pre-Incorporation Expenses Disclosed Bona Fide Does Not Attract Section 270A Penalty

By | July 25, 2026
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Inadvertent Claim Of Full Pre-Incorporation Expenses Disclosed Bona Fide Does Not Attract Section 270A Penalty Issue Levy of Penalty under Section 270A for Inadvertent Expense Claim: Whether penalty under Section 270A for under-reporting of income can be levied when an assessee inadvertently claims 100% of pre-incorporation expenses instead of 1/5th under Section 35D, but offers… Read More »

CIT(A) Cannot Set Aside Section 147 Reassessment Order as Power Is Restricted to Section 144

By | July 25, 2026
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CIT(A) Cannot Set Aside Section 147 Reassessment Order as Power Is Restricted to Section 144 CIT(A) Cannot Set Aside Section 147 Reassessment Order as Power Is Restricted to Section 144 Issue CIT(A) Jurisdiction to Remand Section 147/144B Assessments: Whether the Commissioner (Appeals) has the jurisdiction under Section 251(1)(a) to set aside an assessment order framed… Read More »

CIT(A) Order Dismissing Appeal In Limine Without Requested Hearing Violates Natural Justice Requiring Remand

By | July 25, 2026
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CIT(A) Order Dismissing Appeal In Limine Without Requested Hearing Violates Natural Justice Requiring Remand Issue Violation of Natural Justice in Delay Condonation Order: Whether a dismissal order passed in limine by the CIT(A) rejecting an application for condonation of delay without granting a requested personal/virtual hearing violates principles of natural justice, requiring the matter to… Read More »

Section 148 Reassessment Notice Issued Beyond Ten-Year Block Period Calculated From Search Date Is Time-Barred

By | July 25, 2026
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Section 148 Reassessment Notice Issued Beyond Ten-Year Block Period Calculated From Search Date Is Time-Barred Section 148 Reassessment Notice Issued Beyond Ten-Year Block Period Calculated From Search Date Is Time-Barred Issue Computation of Ten-Year Block Period under Section 153A/153C: Whether the assessment year relevant to the previous year in which the search was conducted is… Read More »

Reassessment Order Set Aside Where Show Cause Notice Cited Figures From Different Assessment Year

By | July 25, 2026
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Reassessment Order Set Aside Where Show Cause Notice Cited Figures From Different Assessment Year Reassessment Order Set Aside Where Show Cause Notice Cited Figures From Different Assessment Year Issue Validity of Reassessment Order Based on Mismatched Show Cause Notice: Whether a reassessment order passed under Section 147 read with Sections 144 and 144B can be… Read More »

Rejection Of Condonation For Delayed Section 80P Return By Co-Operative Society Set Aside Liberal Approach Required

By | July 25, 2026
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Rejection Of Condonation For Delayed Section 80P Return By Co-Operative Society Set Aside Liberal Approach Required Rejection Of Condonation For Delayed Section 80P Return By Co-Operative Society Set Aside Liberal Approach Required Issue Condonation of Delay under Section 119(2)(b) for Section 80P Deduction: Whether a co-operative society’s application seeking condonation of delay under Section 119(2)(b)… Read More »