The ITAT held that the alleged bogus purchases could not stand when the assessee produced complete documentary evidence showing genuine procurement and consumption. With no contrary evidence from the AO, the 69C addition was removed.
The Tribunal held that once the 29.03.2022 Scheme came into force, only faceless units could issue such notices; a JAO-issued notice was illegal, nullifying the entire reassessment.
ITAT Chennai ruled that Section 148 notices issued manually by a Jurisdictional AO after 29.03.2022 violate the faceless reassessment procedure. The Tribunal quashed the reassessment order, emphasizing that only NFAC-issued notices are legally valid.
Arulmigu Vettudaiyar Kaliamman Thirukovil Vs ITO (ITAT Chennai) Assessee challenged reassessment solely on the legal ground that notices u/s 148 dated 31.03.2022 (AY 2015-16) & 29.03.2023 (AY 2016-17) were issued by the Jurisdictional AO (JAO) instead of the Faceless Unit, contrary to Sec.151A & CBDT’s Faceless Reassessment Scheme notified on 29.03.2022, which mandates automated/faceless issuance […]
ITAT Chennai held that a notice issued u/s 148 by the Jurisdictional AO after 29.03.2022 violates the mandatory faceless assessment scheme. Consequently, the reassessment and all subsequent actions, including penalty, were declared null and void.
ITAT Kolkata deletes ₹7.84 crore addition on F&O and currency-derivative losses as AO relied solely on a now-vacated SEBI interim order. Tribunal emphasized that the assessee submitted full documentary evidence, which remained unrebutted, confirming losses as genuine.
Tribunal remands ₹88 lakh disallowance of long-term service award to the AO for fresh verification as employee-wise computation for the relevant year was not on record. Claim can be allowed only after proper quantification of ascertained liability.
The Revenue relied on third-party statements and WhatsApp data to allege an unrecorded ₹25 crore cash loan, but brought no supporting inquiry or cross-examination. The Tribunal held that the AO’s conclusion was speculative, especially when bank-backed evidence, TDS records, and a registered loan agreement supported only a ₹10 crore loan. Key takeaway: additions under Section 69A require concrete evidence, not assumptions.
ITAT Lucknow restored the reassessment u/s 147 after holding that CIT(A) misread the AO’s findings and wrongly assumed verification of books and cash deposits. The Tribunal found the appellate order perverse and allowed the Revenue’s appeal.
The ITAT Pune held that splitting royalties for domestic vs export sales was impermissible, deleting the entire transfer pricing adjustment. The ruling reinforces that TNMM aggregation for manufacturing includes royalties as a single element.
