TMI BlogLandmark Income Tax Reassessment CaseX X X X Extracts X X X X X X X X Extracts X X X X ..... e return filed for the assessment year 2016-2017. This reassessment notice, issued under Section 148 of the Income Tax Act 1961, became the focal point of a legal battle challenging its validity on several grounds. Core Legal Issues * Classification of Expenditure: Central to the dispute was whether certain expenses should be classified as capital or revenue expenditure, significantly affecting ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ocused on the following aspects: * Invalidity of the Notice: The Court determined the reassessment notice to be invalid, primarily due to it being issued after the permissible three-year period following the relevant assessment year. Moreover, the required approval for the notice was not obtained from the appropriate authority as mandated by the Act. * Application of TOLA: The Court found that ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... in India. It offers critical insights into the procedural and legal intricacies of income tax reassessment, serving as a vital guide for both tax authorities and taxpayers. For tax authorities, the judgment is a reminder of the stringent adherence required to the legislative framework and procedures in reassessment cases. It highlights the need for meticulous compliance with legal provisions to u ..... X X X X Extracts X X X X X X X X Extracts X X X X
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