ITAT quashed a reassessment, ruling that S 148 notice was invalid because it was issued before AO formally received mandatory sanction from PCIT under S 151. Relying on Supreme Court, Tribunal held that internal approval is insufficient; communication of sanction to AO is a jurisdictional prerequisite.
Tribunal observed that AO accepted returned income without any independent examination or inquiry. As major issues like estimation of profit in liquor trade and tax audit requirements were ignored, assessment was held erroneous. Pr. CIT’s revision under Section 263 was sustained.
ITAT set aside ex-parte additions for unsecured loans and partner’s capital, ruling that taxpayer had reasonable cause for late submission of evidence due to departure of their accountant and Authorized Representative (AR). Tribunal directed CIT(A) to admit evidence under Rule 46A and decide case on its merits.
The Andhra Pradesh High Court definitively ruled that Jurisdictional Assessing Officers (JAOs) lack the authority to issue reassessment notices (u/s 148A/148) after the Faceless Assessment Scheme (Section 151A) was notified in 2022. The court quashed the notices and orders, establishing that the faceless mechanism is the exclusive forum for initiating reassessment proceedings.
Tribunal reversed disallowance of Section 80P deduction, affirming that interest income earned by a co-operative society from deposits with a co-operative bank is eligible for tax benefit.
ITAT ruled that a resident individual, opting for new tax regime with income below ₹7 lakhs, is eligible for full S 87A rebate, even if their income includes STCG under S 111A3 Court held that no statutory bar existed for Assessment Year 2024-25, invalidating system-driven denial by CPC.
Tribunal ruled that high-rate tax under Section 115BBE cannot be applied to assessment year 2017-18 cash deposit, as section applies only to transactions on or after April 1, 2017. Decision directs AO to compute consequential tax liability under normal provisions.
ITAT Delhi deleted a ₹31.35 lakh addition for alleged inflated purchases, ruling that an assessment cannot rest solely on third-party search data. The Tribunal emphasized that the Revenue failed to conduct any independent enquiry or provide corroborating evidence linking the assessee to the alleged cash transactions.
ITAT Delhi remanded the addition of 12.5% profit on alleged bogus sales because the CIT(A) sustained the amount (₹20.16 lakh) without providing adequate reasoning or opportunity to the assessee. The Tribunal directed the CIT(A) to pass a fresh, speaking order after considering all submissions.
ITAT Delhi condoned a significant delay in filing appeals, ruling the cause was bona fide as the accountant’s linked email ID led to the non-receipt of assessment and penalty notices. The Tribunal set aside the ex-parte assessment and penalty, remanding the case for a fresh hearing on merits.
