HC ruled that the Assessing Officer (AO) cannot reopen ...

High Court Strikes Down Tax Reassessment Notice, Finds No Valid Grounds for Reopening Beyond Statutory Six-Year Window Under Section 153A

May 3, 2025

Case Laws Income Tax HC

HC ruled that the Assessing Officer (AO) cannot reopen assessment for AY 2016-17 under Section 153A, as it falls outside the six-year block period following a search action. The notice was invalid because: (1) no asset-related income escape was established, (2) expenses disallowance did not meet statutory criteria for reopening, and (3) the assessment year exceeded the permissible limitation period. The search conducted in FY 2022-23 only allows reassessment for AY 2017-18 through AY 2023-24. Consequently, the HC set aside the impugned notice and terminated the reassessment proceedings.

View Source

← Previous Next →

HC ruled that the Assessing Officer (AO) cannot reopen ...

High Court Strikes Down Tax Reassessment Notice, Finds No Valid Grounds for Reopening Beyond Statutory Six-Year Window Under Section 153A

May 3, 2025

Case Laws Income Tax HC

You may also like:

HC upheld tax reassessment proceedings for AY 2009-2010, finding valid jurisdictional grounds for reopening assessment. The court determined that information about bogus...

The High Court quashed the reassessment proceedings initiated by the Assessing Officer u/s 148 of the Income Tax Act, holding it to be a case of "change of opinion" and...

The case pertains to the validity of reopening an assessment u/s 147 of the Income Tax Act. The crux lies in determining whether the reassessment proceedings can...

HC quashed reassessment notice under s.148 concerning lease payments, foreign currency transactions, and goodwill depreciation. Court found no valid grounds for...

HC dismissed Revenue's appeal challenging reopening of assessment u/s 147. The court found no valid grounds for reassessment as there was no failure by assessee to...

HC held that the tax authority's reopening of assessment against the mutual fund was invalid. The notice contained discrepancies between alleged fund manipulation and...

Validity of reopening an assessment and the legality of issuing a new Show Cause Notice u/s 148-A(b) after the conclusion of initial reassessment proceedings. The key...

ITAT adjudicated a tax reassessment case involving procedural irregularities in notice service. The tribunal found that the Revenue department failed to substantiate...

ITAT held that once the Assessing Officer (AO) is satisfied with the reasons recorded for reopening the case and abstains from making additions on the specific grounds...

HC upheld the reassessment proceedings against the taxpayer, finding the AO's reopening of the assessment valid. The court determined that the statutory provisions do...

HC invalidated reassessment proceedings against the petitioner under Section 148A, finding a critical procedural defect. The AO's notice failed to substantiate the claim...

Reopening of assessment under s.147 challenged on grounds of invalid notice under s.143(2) and "change of opinion." ITAT held notice under s.143(2) was valid as return...

Reopening of assessment u/s 147 or assessment u/s 153C - reassessment was made based on the materials found in the course of search conducted on third party - The...

The ITAT held that the reassessment notice u/s 148 for AY 2014-15 and AY 2015-16 was time-barred. For AY 2014-15, the assessee failed to respond within the two-week...

This judgment deals with the validity of reassessment notices issued u/s 148 of the Income Tax Act between July and September 2022, in light of the Tax Ordinance and the...

Quick Updates: