Tag Archives: HIGH COURT OF GUJARAT

Reassessment Notice Based on Loose Seized Notings Lacking Direct Link to Assessee Is Quashed Issue Whether the Assessing Officer (AO) can validly issue a reassessment notice under Section 148 on the presumption of “on-money” payment, based solely on an entry in a third-party seized register that was recorded 23 months prior to the actual land… Read More »

Order and Notice Under Section 148A Passed Ignoring Recorded Adjournment Request Are Legally Void Order and Notice Under Section 148A Passed Ignoring Recorded Adjournment Request Are Legally Void Issue Whether an order passed under Section 148A(d) and a consequential notice issued under Section 148 of the Income-tax Act, 1961, are legally sustainable when the Assessing… Read More »

Reopening Assessment Based Solely on Illegible Third-Party Loose Papers Lacking Nexus is Wholly Unsustainable Issue Whether the revenue is legally justified in reopening an assessment under Section 147 and issuing a notice under Section 148 based entirely on an illegible loose paper seized from an unrelated third party, where the satisfaction note fails to establish… Read More »

Reassessment Notice Quashed as Seized Third-Party Loose Paper Failed to Establish a Live Link Reassessment Notice Quashed as Seized Third-Party Loose Paper Failed to Establish a Live Link Issue Whether a reassessment notice issued under Section 148 to tax alleged “on-money” under Section 69A is valid when it is based solely on a third-party seized… Read More »

An assessment order is legally unsustainable and deemed unreasoned if it summarily treats bank credits as unexplained under Section 68 without evaluating the explanation offered by the taxpayer. Issue Whether a reassessment order passed under Section 147 read with Section 144B is legally valid if the Assessing Officer (AO) summarily treats book-entered bank credits as… Read More »