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Reassessment Quashed: AO Lacked Jurisdiction Under Faceless Regime Section 151A

October 25, 2025 879 Views 0 comment Print

Karnataka High Court set aside reassessment proceedings for AY 2020-21, ruling the jurisdictional Assessing Officer acted beyond the scope of Section 151A (Faceless Assessment). The decision reinforces that reassessment notices must strictly follow the procedural mandate of the faceless regime, though the Revenue retains the liberty to revive the case if the Supreme Court validates the procedure.

Tribunal Rejects 15-Year-Old PMLA Appeals Over Unexplained Delay

October 25, 2025 543 Views 0 comment Print

Appellate Tribunal under SAFEMA dismissed PMLA appeals filed after 5270 days, ruling that excessive delay and lack of vigilance by the appellants made the appeals legally untenable.

ED Fails to Prove HSBC Geneva Account, FEMA Charges Dropped

October 25, 2025 1164 Views 0 comment Print

Appellate Tribunal dismissed FEMA proceedings after the ED could not provide authenticated HSBC Geneva bank statements. The ruling emphasizes that unverified evidence cannot support prosecution.

Tribunal Confirms Property Attachment Linked to LIC Commission Under PMLA

October 25, 2025 588 Views 0 comment Print

The tribunal ruled that commissions earned through LIC policies linked to a scheduled offence were rightly treated as proceeds of crime, justifying provisional attachment of property.

Re-assessment Quashed as Notice Issued by PCIT instead of Principal Chief Commissioner

October 25, 2025 837 Views 0 comment Print

The ITAT Pune quashed reassessment proceedings, ruling them void ab initio because the requisite approval under Section 151(ii) was granted by the Principal Commissioner of Income Tax (PCIT) instead of the Principal Chief Commissioner (PCCIT). This failure to follow the mandatory jurisdictional hierarchy for notices issued after three years vitiated the entire reopening.

Unexplained Income Reduced from ₹10 Cr to ₹2.22 Cr, Commission to 1% in entry transaction case

October 25, 2025 432 Views 0 comment Print

ITAT Delhi partly allowed assessee’s appeal, reducing unexplained income from ₹10.08 crore to ₹2.22 crore and lowering commission on inter-mediated transactions from 3% to a fair 1%, emphasizing verification of cash and cheque entries under same code.

CBDT issues Income Tax Search & Seizure Manual 2025

October 25, 2025 17289 Views 0 comment Print

CBDT’s 2025 Search & Seizure Manual guides tax officers on lawful, tech-driven investigations under Sections 132–132B of the Income Tax Act.

ITAT Delhi Deletes 25% “Bogus Sales” Disallowance; Section 37 Not Applicable to Sales

October 24, 2025 990 Views 0 comment Print

ITAT Delhi held that sales made to Jyoti Products were genuine, supported by ledgers and invoices. The 25% disallowance by the AO under Section 37 was deleted, as Section 37 applies only to business expenditure, not sales transactions.

No Office, No Expatriates, No PE: ITAT Delhi Rejects Revenue’s Repeated PE Allegation

October 24, 2025 627 Views 0 comment Print

ITAT Delhi held that the absence of office premises and expatriate activity meant the assessee had no Permanent Establishment (PE) in India. The Tribunal ruled that Revenue cannot rely solely on past orders without verifying current-year facts.

ITAT Quashes 263 Order as PCIT Withheld Adverse Material & Ignored Evidence of Genuine Purchases

October 24, 2025 543 Views 0 comment Print

The ITAT ruled that the PCIT wrongly invoked Section 263 by relying on unverified external information (e.g., SEBI data and license suspension claims) to label purchases as bogus, without providing this information to the assessee for rebuttal. The tribunal deleted the revisionary order, confirming that the PCIT acted illegally by presuming facts and ignoring the documentary proof of purchase genuineness.

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