The Karnataka High Court set aside the reassessment (u/s 147 and 148) because the jurisdictional AO issued notices, violating the Section 151A mandate for faceless reassessment. The ruling reinforces that all orders based on notices issued outside the scheme’s scope are void and stand quashed.
The Karnataka High Court set aside the reassessment notices (u/s 148A and 148) because the jurisdictional AO issued them, violating the mandate of Section 151A under the faceless scheme. The ruling confirms that notices issued outside the centralized, faceless framework are invalid and without authority.
The Karnataka High Court set aside the reassessment proceedings, including Section 148A and consequential penalty orders, ruling they were initiated without jurisdiction. The court found that the jurisdictional AO issued notices outside the scope of Section 151A, violating the CBDT’s faceless scheme.
The Karnataka High Court set aside the ex parte assessment, penalty, and demand orders passed under Sections 143(3) and 144B, accepting the taxpayer’s plea of bona fide non-appearance. The court adopted a justice-oriented approach, remitting the case back to the Assessing Officer for a fresh consideration from the show-cause notice stage.
The Karnataka High Court struck down an Income Tax attachment under Section 281B because the property was exclusively owned by a non-assessee petitioner who acquired it through valid transactions. The court ruled that tax recovery cannot attach property not belonging to the actual assessee, making the order illegal.
ITAT Bengaluru held that cancellation of charitable registration under Section 12AB(4) cannot operate retrospectively for years prior to AY 2022-23. The order of the PCIT (Central) cancelling the trust’s registration for earlier years was quashed as legally untenable.
The Kolkata ITAT deleted a Rs.31 crore unexplained cash credit addition under Section 68 on the sale of shares, ruling the AO mechanically relied on an investigation report without fresh evidence. The tribunal held that investments accepted by the Department in previous years and confirmed via an NCLT merger cannot be summarily taxed upon sale.
The Kolkata ITAT quashed the Section 263 revision, confirming that the Assessing Officer (AO) had specifically examined and accepted the ICDS adjustments during scrutiny. The tribunal held that when the AO conducts due inquiry and takes a plausible view, the assessment is neither erroneous nor prejudicial to the Revenue’s interest.
The Karnataka High Court struck down the Section 148 reassessment notice for being issued outside the jurisdiction/scope defined by Section 151-A. This decision invalidates the subsequent assessment, penalty, and demand, pending a final verdict from the Supreme Court on the core legal issue.
The Karnataka High Court dismissed the Revenue’s appeal, confirming that payments for software usage to a non-resident are not taxable as royalty under the Income Tax Act or DTAA. The court held the issue was conclusively settled by its own and the Supreme Court’s prior rulings in the assessee’s and similar cases.
