Delhi High Court judgment on validity of Section 148 Income Tax notices issued March 31, 2021 but despatched after April 1, 2021. Court held mere generation doesn't constitute issuance - despatch required for validity under amended limitation provisions.
Supreme Court resolves Section 148 notice controversy affecting 90,000 reassessment cases. Landmark judgment on Finance Act 2021 amendments, Section 148A procedure, and Article 142 powers in tax law.
SC ruling on income tax reassessment notices validity post-April 2021. Clarifies TOLA application, Finance Act 2021 changes & Ashish Agarwal scope.
ITAT Delhi deletes Section 68 additions in Kuber Group cases. Landmark precedent on search assessments and independent inquiry obligations.
No penalty is justified for initial non-compliance with a Section 142(1) notice if the taxpayer subsequently makes good the default and the assessment is completed under Section 143(3) after considering all submissions.
Payments towards CAM charges are in the nature of contractual payments for services, not rent for use of premises/equipment. They therefore attract TDS at 2% under Section 194C, not Section 194I.
Rectification is not a substitute for review or reassessment, especially in contentious matters like Section 14A disallowances.
The law does not prohibit all dealings with specified persons; Section 13 only bites if there is actual benefit. Purely facilitating the charitable object, even via related parties, is not disqualifying unless benefit is demonstrated.
Recognizing conflicting views on the computation of “due date”—whether it runs from the month salary is paid or the month salary accrues—the ITAT Delhi remanded the issue back to the AO.
An invalid order cannot give birth to legally valid proceedings. A void reassessment order cannot be the subject matter of revision under Section 263.