Just a moment...

Top
Help
×

By creating an account you can:

Logo TaxTMI
Call Us / Help / Feedback

Contact Us At :

E-mail: [email protected]

Call / WhatsApp at: +91 99117 96707

For more information, Check Contact Us

FAQs :

To know Frequently Asked Questions, Check FAQs

Most Asked Video Tutorials :

For more tutorials, Check Video Tutorials

Submit Feedback/Suggestion :

Email :
Please provide your email address so we can follow up on your feedback.
Category :
Description :
Min 15 characters 0/2000
Make Most of Text Search
  1. Checkout this video tutorial: How to search effectively on TaxTMI.
  2. Put words in double quotes for exact word search, eg: "income tax"
  3. Avoid noise words such as : 'and, of, the, a'
  4. Sort by Relevance to get the most relevant document.
  5. Press Enter to add multiple terms/multiple phrases, and then click on Search to Search.
  6. Text Search
  7. The system will try to fetch results that contains ALL your words.
  8. Once you add keywords, you'll see a new 'Search In' filter that makes your results even more precise.
  9. Text Search
Add to...
You have not created any category. Kindly create one to bookmark this item!
Create New Category
Hide
Title :
Description :
❮❮ Hide
Default View
Expand ❯❯
Close ✕
🔎 Highlights - Adv. Search
TEXT SEARCH:

Press 'Enter' to add multiple search terms. Rules for Better Search

Search In:
Main Text + AI Text
  • Main Text
  • Main Text + AI Text
  • AI Text
Law:
---- All Laws----
  • ---- All Laws----
  • Income Tax
  • Direct Taxes
  • Benami Property
  • Central GST Laws
  • SGST - State GST Laws
  • Customs
  • FTP - Foreign Trade Policy
  • SEZ - Special Economic Zone
  • FEMA - Foreign Exchange Management
  • Companies Law
  • SEBI - Securities & Exchange Board of India
  • IBC - Insolvency and Bankruptcy
  • Law of Competition
  • PMLA - Money-Laundering
  • Indian Laws
  • Bill / Finance Bills
  • Wealth Tax
  • Service Tax
  • Central Excise
  • VAT / Sales Tax
Month:
---- All Months ----
  • ---- All Months ----
  • January
  • February
  • March
  • April
  • May
  • June
  • July
  • August
  • September
  • October
  • November
  • December
Year:
---- All Years ----
  • ---- All Years ----
  • 2026
  • 2025
  • 2024
  • 2023
  • 2022
  • 2021
  • 2020
  • 2019
  • 2018
  • 2017
  • 2016
  • 2015
  • 2014
  • 2013
  • 2012
  • 2011
Sort By: ?
In Sort By 'Default', exact matches for text search are shown at the top, followed by the remaining results in their regular order.
Relevance Default Date
    Corroborative Evidence required: seizures and duty demands unsupported by input output theory were set aside for lack of positive proof.
    Surcharge on tax leviable in addition to tax on declared goods when computed on tax payable.
    Limitation period exclusion requires fresh adjudication of refund claims; administrative rejections cannot ignore the judicial exclusion.
    Right to Personal Hearing: ineffective portal-only service requires alternate modes and fresh hearing before adjudication.
    Effective service requirement: officers must explore alternative service modes beyond the GST portal and afford personal hearing; non-compliance voids...
    Cancelled transactions and reversal of consideration negate taxable income; assessments quashed where cancellation evidence was not considered.
    Invocation of Section 153C: reliance on external or public domain material or absence of AO satisfaction note invalidates proceedings.
    Computation of limitation for reopening: ten-year window reckoned from end of the relevant assessment year, notice quashed.
    Estimate-based additions do not satisfy proof-of-concealment required for penalty; penalty deleted where addition rests on estimate.
    Estimation of profit element in bogus purchases remitted for fresh adjudication to apply binding precedents and record reasons.
    Estimation of undisclosed income on turnover is unsustainable where banking evidence and books support transactions, so additions deleted.
    Limitation under Section 153(3) bars final assessments if DRP directions are issued after the prescribed statutory window.
    Permanent Establishment under DTAA not established, so off the shelf software receipts not taxable as royalty and presumptive tax inapplicable.
    Arm's length price: Internal CUP remand for NCD benchmarking; fresh deduction claim admitted and statutory interest on refund directed.
    Onus to Prove Genuineness of Share Transactions: documentary proof can rebut suspicion and protect 10(38) LTCG exemption.
    Admission of Additional Grounds affirmed where facts are on record; reopening quashed when additions do not flow from recorded reasons.
    Permanent Establishment and Business Connection: foreign consultancy receipts not attributable where no fixed base or corporate veil piercing establis...
    Transfer Pricing: royalty adjustment negated by prior appellate precedent; typographical error did not defeat infrastructure deduction claim.
    Relevant date for Section 54 exemption: completion with payment and possession within two years qualifies for relief.
    Customs Valuation Rule sequence: Chartered Engineer certificate alone cannot justify rejection of transaction value; reassessment set aside.
❯❯
Maximize Maximize Maximize
0 / 200
Expand Note
Add to Folder

No Folders have been created

+

Are you sure you want to delete "My most important" ?

NOTE:

Highlights
Showing Results for :
Reset Filters
Results Found:
Show All Summaries Hide All Summaries

Highlights

Back

All Highlights

Showing Results for :
Reset Filters
No Records Found

Highlights

Back

All Highlights

whatsapp Join Channel
Showing Results for : Reset Filters

Assessment under section 147 read with section 144B was not...

Faceless reassessment remains valid where section 143(2) notice is issued competently, but merit additions were remanded for fresh verification.

Contents
Summary
Note

Note

-

Bookmark

Print

Print

Income Tax March 30, 2026 Case Laws AT
Assessment under section 147 read with section 144B was not vitiated merely because notice under section 143(2) was issued by the Jurisdictional Assessing Officer and the reassessment was completed through the faceless regime; the Tribunal held that concurrent jurisdiction survives and rejected the legal challenge. On merits, however, additions based on treating full sale consideration as short-term capital gain, ad hoc estimation of contract and professional receipts, and addition of rent receipts as business income were set aside because they were made without proper verification of cost, books, reconciliation, or supporting documents. The matter was remanded for fresh examination, with the assessee's non-compliance noted as a material factor.

Topics

Acts Income Tax