ITAT Surat allowed a company to avail concessional tax rates under Section 115BAA despite a minor delay in filing Form 10-IC due to portal issues, emphasizing a practical approach.
Chennai ITAT ruled that a 148 notice issued by JAO post-CBDT faceless scheme notification is invalid, quashing reassessment and penalty. The tribunal confirmed that only notices issued by the Faceless Assessment Unit are legally valid.
ITAT Chennai annulled the Section 148-based reassessment for AY 2018-19 because the notice contravened the e-assessment scheme under Sec.151A. The ruling reinforces mandatory compliance with faceless notice issuance.
ITAT Pune held that the CIT(A) failed to adjudicate key legal grounds, including wrong AO jurisdiction and missing Document Identification Number. Entire order under Section 144 r.w.s. 263 was set aside for reconsideration with proper hearing.
The ITAT ruled that a Section 148 notice issued by a Jurisdictional AO after 29.03.2022 is invalid because, under the Faceless Reassessment Scheme, only the Faceless Assessing Officer can issue such notices. The entire reassessment was therefore quashed as without jurisdiction.
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.
