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Section 148 Notice Invalidated for Genuine Non-Filing of Return

December 20, 2025 561 Views 0 comment Print

Karnataka High Court set aside reassessment and penalty orders where the assessee could not file returns due to inactive email, granting a fresh opportunity to submit documents and pleadings.

Reassessment Quashed for Lack of Opportunity to Reply to Section 148 Notice

December 20, 2025 327 Views 0 comment Print

The issue involved reassessment completed without a reply to the reopening notice. The Court set aside the orders and remanded the case to allow the assessee a fresh opportunity.

Reassessment Quashed for Initiation Outside Section 151A Scope

December 20, 2025 423 Views 0 comment Print

Karnataka High Court invalidated reassessment proceedings and related notices for AY 2015-16, holding that actions initiated beyond Section 151A are legally void.

DRP Upload Date Triggers Limitation – Final Order Passed Late Is Void ab initio

December 20, 2025 546 Views 0 comment Print

The ITAT held that limitation under section 144C(13) starts from the date DRP directions are uploaded on the ITBA portal. A final order passed beyond this deadline was declared void ab initio.

CPC Adjustment Set Aside Because Delay Condonation Was Not Decided

December 20, 2025 471 Views 0 comment Print

The ITAT held that CPC and CIT(A) acted prematurely in denying section 80P deduction while a section 119 condonation application was awaiting decision. The matter was remanded for fresh adjudication after condonation is decided.

Will-Based Mutation Cannot Be Rejected Merely on Objection by Third Party

December 20, 2025 1251 Views 0 comment Print

The issue was whether mutation could be refused solely because it was sought on the basis of a will. The Supreme Court held that such refusal was erroneous and restored mutation, clarifying that mutation is fiscal and subject to civil adjudication.

Reassessment Quashed Because Section 151 Sanction Was Mechanical

December 20, 2025 726 Views 0 comment Print

The ITAT held that approval merely stating “Yes, I am satisfied” shows no application of mind. Such sanction fails the statutory requirement and invalidates reopening.

Repaid Loans and Bank Entries Can’t Trigger Section 68

December 20, 2025 747 Views 0 comment Print

The ITAT held that loans and advances accepted in earlier scrutiny assessments cannot be doubted later without fresh incriminating material. Mere balance-sheet analysis or suspicion is insufficient.

JAO Can’t Bypass Faceless Mandate – U/s 148 Notice Issued Outside Scheme Quashed

December 20, 2025 1017 Views 0 comment Print

The ITAT held that a reassessment notice issued by the Jurisdictional AO after 29-03-2022 violated the mandatory faceless reassessment scheme. Such a jurisdictional lapse vitiates the entire proceedings.

Less Than 7 Days’ Reply Time Voids Faceless Assessment

December 20, 2025 969 Views 0 comment Print

The High Court held that granting less than seven days to reply to a show-cause notice violates mandatory SOPs. Such a breach vitiates the entire faceless assessment process.

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