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2025 (3) TMI 2180
Case Laws Income Tax
Reassessment limitation for Assessment Year 2015-16 invalidated a delayed notice and required quashing of the consequential reassessment order.
Reassessment notices for Assessment Year 2015-16 had to be issued by 31 March 2022 under the applicable limitation framework. A notice issued on 31 July 2022 was beyond that outer date. Applying the Revenue's concession recorded in the governing Supreme Court ruling, post-1 April 2021 notices for that assessment year were required to be dropped where reassessment could not be completed within the period preserved by the relevant extension regime. The time-barred notice was invalid, and the consequential reassessment order was quashed.

2025 (3) TMI 2181
Case Laws Income Tax
Stamp duty valuation additions require consideration of the valuation report before a fresh determination is made after hearing the assessee.
Addition based on stamp duty value under section 43CA requires consideration of the valuation report obtained on the Assessing Officer's accepted reference. The assessment had been completed due to limitation, expressly subject to modification upon receipt of that report, but the subsequently determined fair market value was not considered. A fresh determination after considering the valuation report and providing the assessee a reasonable opportunity was required. The assessment was remanded for fresh adjudication, and the addition was not sustained for final determination.

2026 (2) TMI 1460
Case Laws Income Tax
Reassessment jurisdiction fails when a different officer completes assessment without valid transfer or issuing a fresh statutory notice.
Reassessment jurisdiction requires the officer completing the assessment to hold valid authority through a transfer of jurisdiction or to issue the statutory reassessment notice. Where one Assessing Officer issued the notice under Section 148 and another completed the reassessment without a demonstrated transfer order under Section 127 or a fresh notice, the latter lacked jurisdiction to frame the assessment. The reassessment was therefore invalid and quashed. A contrary precedent concerning PAN-based jurisdiction and restructuring of charges was distinguishable on its facts.

2026 (3) TMI 1742
Case Laws Income Tax
Reassessment jurisdiction requires valid transfer and notice by the completing officer; defects render proceedings void from inception.
Reassessment requires the officer completing it to hold validly transferred jurisdiction and to issue the statutory notice initiating reassessment. Where proceedings are initiated by one Assessing Officer but concluded by another, a valid transfer order is necessary; absence of such authority is a jurisdictional defect that cannot be waived and renders the reassessment void. Issuance of notice under section 148 by the officer assuming reassessment jurisdiction is also an indispensable precondition. Consequently, reassessment completed without a traceable transfer order and without notice issued by the completing officer is void ab initio; consequential proceedings do not survive, and merits issues become academic.

2026 (3) TMI 1743
Case Laws Income Tax
Competent reassessment sanction after three years requires approval from the prescribed authority; earlier show-cause approval cannot substitute it.
For reassessment notices issued after three years from the end of the relevant assessment year, the competent sanctioning authority must be identified as of the notice date. Approval for an earlier show-cause notice does not replace the distinct statutory approval required for the reassessment notice and resulting assessment order. Where approval was obtained from the Principal Commissioner rather than the Principal Chief Commissioner, the reassessment notice was invalid and the assessment based on it was liable to be quashed.

2025 (7) TMI 2059
Case Laws Income Tax
Reassessment limitation under Section 149 barred post-April 2021 notices for Assessment Year 2015-16 despite TOLA extension.
Reassessment notices for Assessment Year 2015-16 issued on or after 1 April 2021 were barred by limitation where the applicable period under Section 149 had expired. The extended period preserved by TOLA did not permit completion of reassessment proceedings beyond that limitation. Proceedings initiated under Section 148A(b) after expiry of the six-year period were likewise time-barred. Consequently, a notice issued under Section 148 for that assessment year was invalid.

2026 (2) TMI 1461
Case Laws Income Tax
Recall of appellate order denied where disputed grounds were already considered and rejected in the original decision
The Tribunal's refusal to recall its appellate order was upheld because the disputed grounds had already been considered and rejected in the original order. The High Court found that the Tribunal had addressed the allegation of non-adjudication by referring to the relevant portions of its prior decision, and no basis for appellate interference was established. The issue was therefore decided against the assessee.

2026 (1) TMI 1661
Case Laws GST
Operational GST Appellate Tribunal restores statutory appeal route, leading to disposal of writ petition without examining challenged orders.
Constitution of the GST Appellate Tribunal, appointment of its Members, and notification of procedural rules made the statutory appellate mechanism operational. As the writ petition had been entertained only because the Tribunal was previously unavailable, the petition was disposed of with permission to pursue the statutory appeal before the GST Appellate Tribunal. The validity and legality of the impugned orders were not examined.

Tariff values for specified imported edible oils, brass scrap, gold, silver and areca nuts are substituted under the customs valuation framework. The revised tables prescribe tariff values for crude and refined palm oils, palmolein, crude soybean oil and brass scrap on a per-metric-tonne basis; for eligible gold and silver, including specified bars, coins, findings and semi-manufactured silver, on specified weight bases; and for areca nuts. The notification takes effect from 1 August 2026, replacing the corresponding tables in the existing tariff-value notification.

Umarwada, Ankleshwar, Bharuch, Gujarat, is added to the notified Inland Container Depots under the Customs Act framework. The location is authorised for unloading imported goods and loading export goods, including any specified class of such goods. This amends the Customs notification governing places approved for customs handling of import and export cargo.

Anti-dumping duty on imports of untreated fumed silica from China PR is extended under Notification No. 66/2021-Customs (ADD). The duty will remain in force up to and including 10 February 2027, unless it is revoked, superseded, or amended earlier. The amendment inserts a new paragraph overriding the earlier duration provision in paragraph 2 of the principal notification.

Renewal approval permits OSCAR Freight Pvt. Ltd. to operate export bonded trucking for air cargo from Air Cargo Complex, Kolkata to customs-notified airports, ICDs, AFSs and CFSs within India. The permission remains valid for three years or until bond validity expires, whichever is earlier, and restricts movement to closed-body trucks under ECTS seal. Bond debit applies when cargo is collected and credit upon delivery to destination Customs; the transhipper bears liability for shortages or pilferage, including the goods' value and applicable interest, penalty and cess. Bank guarantee submission is waived based on the stated prior transshipment volume. Operations remain subject to specified customs transit, cargo-handling and foreign trade requirements, and permission may be renewed or withdrawn after notice and an opportunity of hearing.

M/s. Sattva Hi-Tech & Conware Pvt. Ltd. is appointed as custodian of imported goods landed at Kamarajar Port, Ennore and received at its container freight station until clearance for home consumption, warehousing or transhipment under the Customs Act, 1962. It is also appointed custodian of export cargo brought into its premises until export from that port. The custodian must comply with section 45 of the Customs Act, the Handling of Cargo in Customs Areas Regulations, 2009, and applicable rules, regulations and instructions. The appointment takes effect from 30 July 2026.

The specified Container Freight Station premises are declared a Customs Area for handling imported FCL and LCL cargo arriving from Kamarajar Port, excluding passenger unaccompanied baggage, and for handling export cargo until export. The declaration incorporates the areas and specifications previously notified, including earlier additions and partial de-notification. Import and export cargo must be handled in accordance with the Handling of Cargo in Customs Areas Regulations, 2009, and applicable Chennai Custom House public notices. The declaration takes effect on 30 July 2026.

Notification No. F. A 3-13-2017-1-V (4) Dated:- 3-2-2026 Madhya Pradesh SGST
Dr. R. K. Sharma, Additional Commissioner of State Tax, Head Office, Indore, is appointed as Appellate Authority for Indore Zone-01 and Jabalpur Zone under the Madhya Pradesh Goods and Services Tax framework. The officer shall exercise all powers and perform all duties assigned to the Appellate Authority for the specified territorial jurisdiction. Earlier appointments on the subject stand superseded to the extent of this appointment, subject to the stated exception.

Circular No. 24/2026-27 Dated:- 3-8-2026 Public Notice Dated:- 3-8-2026 Public Notice
Tariff Rate Quota allocation under the India-Oman Comprehensive Economic Partnership Agreement is opened for specified imports for financial year 2026-27, subject to product-specific quota limits and the procedure in Annexure-VIII of Appendix 2A of the Foreign Trade Policy, 2023. Marble-block applicants must submit a Chartered Engineer certificate on processing capacity, machinery and prior production; marble-product applicants must provide a valid pre-purchase agreement with an Oman supplier; and PET-flake applicants must furnish a Ministry of Environment, Forest and Climate Change no-objection certificate.

Notification No. CT-8-2-2026-Sec-1-V(CT)(5) Dated:- 26-2-2026 Madhya Pradesh SGST
Appeals before the Goods and Services Tax Appellate Tribunal may be filed up to 30 June 2026 where the appealed order was communicated before 1 April 2026. Orders communicated on or after 1 April 2026 are subject to a three-month filing period from communication of the order. The framework is deemed operative from 17 September 2025.

Circular No. PUBLIC NOTICE NO. 19/2026 Dated:- 1-7-2026 Trade Notice Dated:- 1-7-2026 Trade Notice
SCMTR filing is mandatory for stakeholders operating at New Mangalore and Karwar Ports. Following the proposed disabling of supplementary IGM/EGM processing from 16 June 2026, manifest and transhipment filings must be made only through the SCMTR module. Manual, automated and legacy-format filings for SCMTR-covered modules are not accepted, except in exceptional system-failure circumstances verified by the local Systems Manager.

Circular No. 23/2026-27 Dated:- 3-8-2026 Public Notice Dated:- 3-8-2026 Public Notice
Seven new Standard Input Output Norms are notified under the Chemical and Allied Products product group for specified pharmaceutical and chemical export products. The norms prescribe permissible import inputs and quantities, including inputs for Theophylline, Liraglutide injection, Lumefantrine, specified Meropenem formulations, and ophthalmic solution. Bulk-drug content in ophthalmic solution must conform to the Drug Manufacturing Licence. Regional Authorities may grant Advance Authorisations directly in eligible cases without individual reference to the Norms Committee.

Notification No. CT-4-2-1-2023-Sec-1-V-(CT) (9) Dated:- 31-3-2026 Madhya Pradesh SGST
The deadline for disposal of every covered pending appeal is extended up to 30 June 2026 under the Madhya Pradesh VAT Act. The extension applies to pending appeals under the Madhya Pradesh VAT Act, the Central Sales Tax Act, and specified allied State taxation laws that were required to be disposed of by 28 February 2027 or earlier under the applicable appeal-disposal provisions.

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