The ITAT held that a reassessment notice issued manually by the JAO violates the mandatory Faceless Assessment Scheme. The Tribunal ruled that any Section 148 or 148A notice must originate only from the faceless system, making the JAO-issued notice invalid.
ITAT held that Section 69 cannot apply when the assessee is not proved to own the cash. Unrebutted affidavits established the source, and mere suspicion cannot justify an addition.
Tribunal held that an investment already assessed substantively in another person’s hands cannot again be taxed under Section 69. The case was remanded to avoid double taxation and ensure consistent adjudication.
Tribunal held that a reassessment cannot be triggered solely on another person’s search statement. With no evidence against the assessee, the 147 proceedings and bogus-purchase addition were struck down.
NFAC’s ex-parte dismissal of large 54F claim overturned due to procedural lapses and miscommunication. Assessee granted fresh opportunity to substantiate ₹3.10 Cr exemption claim.
ITAT allows fresh hearing as assessee’s appeal was dismissed because notices were emailed despite opting for postal delivery. Emphasizes importance of respecting communication preferences in tax proceedings.
The Tribunal ruled that Section 68 additions cannot apply when a company maintains no books of account, deleting ₹51 lakh and ₹1.25 crore additions. Confirms that technical defaults cannot override proper accounting requirements.
The Tribunal held that the reassessment was issued 45 days beyond the maximum permissible period under Rajeev Bansal (SC), making the 148 notice invalid. Applying the deemed-notice framework of Ashish Agarwal, it ruled that the AO had “zero surviving days” to act. The reassessment was quashed for being issued after the statutory outer limit.
The Tribunal invalidated an assessment passed without awaiting the Departmental Valuation Officer report, holding that provisional assessments violate section 50C(2) and 143(3). The rectification under section 154 based on later material was also impermissible.
Reassessment notice issued beyond statutory time limit under Section 148 was invalid; Tribunal quashed proceedings for A.Y. 2013-14, emphasizing procedural compliance.
