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Section 148 Notice Issued Beyond Permissible Period After Ashish Agarwal Regime Held Time-Barred; Reassessment Quashed: Saroj Mehndi vs. ITO (Delhi HC)
Facts of the
CaseThe petitioner, Saroj Mehndi, challenged a notice
dated 11.07.2022 issued under Section 148 of the Income-tax Act for Assessment
Year 2014-15 on the ground that it was barred by limitation. An earlier...
Principles of Accounting: Theory and Application
Principles of
Accounting: Theory and ApplicationINTRODUCTION:
ACCOUNTING AS AN INDEPENDENT DISCIPLINEAccounting is not
merely a clerical activity of recording transactions, nor is it a mechanical
extension of finance...
Section 153C Notices Quashed in Absence of Incriminating Material Belonging to Assessee and Having Bearing on Relevant Years: R.C. Jewellers Pvt. Ltd. vs. DCIT (Delhi HC)
Facts of the
CaseThe petitioner, R.C. Jewellers Pvt. Ltd.,
challenged separate notices dated 26.12.2019 issued under Section 153C of the
Income-tax Act for Assessment Years 2012-13 to 2017-18, along with an order
dat...
Principles of Accounting: Theory and Application
Principles of
Accounting: Theory and ApplicationINTRODUCTION:
ACCOUNTING AS AN INDEPENDENT DISCIPLINEAccounting is not
merely a clerical activity of recording transactions, nor is it a mechanical
extension of finance...
Depreciation on Bank Securities, Pension Fund Contribution and Section 14A Disallowance Covered by Earlier Decisions; No Substantial Question of Law: PCIT-7 vs. Punjab and Sind Bank (Delhi HC)
Facts of the
CaseThe Revenue filed an appeal under Section 260A of
the Income-tax Act challenging the order dated 07.02.2024 passed by the Income
Tax Appellate Tribunal in ITA No. 8688/Del/2019 for Assessment Year 201...
Budget 2026: Direct and Indirect Tax Provisions – A Consolidated Statutory, Judicial and Practical Analysis
Budget 2026: Direct and Indirect Tax Provisions – A
Consolidated Statutory, Judicial and Practical Analysis
INTRODUCTION
The Union Budget 2026 represents a decisive phase in India’s tax reform
journey. It is no...
Reassessment Beyond Three Years Invalid Where Alleged Escapement Below ₹50 Lakh and Not Linked to Single Asset or Event; Section 149(1A) Misapplied: Mohd Athar Anjum vs. ACIT (Delhi HC)
Facts of the
CaseThe petitioner, Mohd Athar Anjum, filed his return
of income for Assessment Year 2018-19 on 21.11.2018 declaring total income of
₹19,11,290. A survey under Section 133A was conducted on 01.09.2022 i...
Section 148 Notice Barred Where Escapement for Relevant AY Below ₹50 Lakh; Cumulative Addition Across Years Not Permissible under Section 149: L-1 Identity Solutions vs. ACIT (Delhi HC)
Facts of the
CaseThe petitioner, L-1 Identity Solutions Operating
Company Private Limited, is a company engaged in providing services to its
foreign associated enterprises. During the period 21.03.2023 to 25.03.2023,
...
Order under Section 148A(d) Cannot Travel Beyond Information in Section 148A(b) Notice; Reassessment Quashed for Violation of Natural Justice: J.G.’s Departmental Store vs. ITO (Delhi HC)
Facts of the
CaseThe petitioner, J.G.’s Departmental Store, is a
partnership firm engaged in operating a chain of departmental stores in Delhi,
with more than 90% of its sales being cash sales. For Assessment Year 2...
Assessing Officer Cannot Sit in Appeal over CIT(A); Order Giving Effect Cannot Be Used to Revisit Merits on Strength of Subsequent Supreme Court Judgment: Goodrich Carbohydrates Ltd. vs. ACIT (Delhi HC)
Facts of the
CaseThe petitioner, Goodrich Carbohydrates Ltd., filed
its return of income for Assessment Year 2017-18 on 30.10.2017 declaring total
income of ₹2,26,85,350. The case was selected for scrutiny and asses...