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Section 263 Invalid When PCIT Questions AO’s Pen/Order Without Proof: ITAT Lucknow

October 7, 2025 1089 Views 0 comment Print

The ITAT ruled the PCIT cannot set aside an assessment u/s 263 for ‘inadequate inquiry’ without conducting an independent investigation to establish prejudice to the Revenue.

Denial of Virtual Hearing Vitiates Order – ITAT Pune Restores 12A Rejection for Fresh Adjudication

October 7, 2025 399 Views 0 comment Print

Pune ITAT voids 12A registration rejection as CIT(E) denied the trust a virtual hearing, citing a Bombay HC ruling on natural justice violation.

ESOP Year Mix-Up & Valuation Error – ITAT Pune Sends Case Back for Re-Examination

October 7, 2025 375 Views 0 comment Print

ITAT Pune remands ESOP tax dispute, citing AO/CIT(A) failure to verify year of acquisition and valuation errors, directing fresh assessment to prevent double taxation.

Delhi HC Reaffirms Concurrent JAO–FAO Jurisdiction for Reassessment

October 6, 2025 6468 Views 0 comment Print

Delhi High Court dismisses petitions, reiterating that both Jurisdictional Assessing Officers (JAO) and Faceless Assessing Officers (FAO) have concurrent jurisdiction to issue Section 148 reassessment notices, holding prior High Court ruling (T.K.S. Builders) is binding.

Both Jurisdictional and Faceless Officers Can Issue Reassessment Notices: Delhi HC

October 6, 2025 1125 Views 0 comment Print

Delhi High Court held that under Section 148A of the Income Tax Act, both the Jurisdictional Assessing Officer and Faceless Assessing Officer possess concurrent jurisdiction to issue reassessment notices, reaffirming its earlier ruling in TKS Builders Pvt. Ltd.

Delhi HC Confirms Concurrent Jurisdiction of JAO and FAO for Section 148 Proceedings

October 6, 2025 918 Views 0 comment Print

Reiterating its view from K.S. Builders Pvt. Ltd., the Delhi HC held that both Jurisdictional and Faceless Assessing Officers have concurrent powers to issue reassessment notices under Section 148 of the Income Tax Act.

No Exclusive Right for Faceless AO: Delhi HC Reiterates Dual Jurisdiction Under Section 148

October 6, 2025 621 Views 0 comment Print

Delhi High Court’s ruling in Neena Wadhwa v. PCIT upholds the concurrent power of both the Jurisdictional Assessing Officer (JAO) and the Faceless Assessing Officer (FAO) to issue reassessment notices under Section 148, citing the binding precedent of T.K.S. Builders Pvt. Ltd..

ITAT Hyderabad Deletes CPC Adjustments – Double Disallowance & Wrong 43B Addition Quashed

October 4, 2025 717 Views 0 comment Print

ITAT Hyderabad deletes CPC adjustments for Caspian Impact Investments. Quashes double disallowance of Section 37(1) loss and Section 43B addition on transferred, carried-forward liability.

No addition for Medical College Donation Based Solely on Third-Party Evidence

October 4, 2025 495 Views 0 comment Print

Hyderabad ITAT quashes ₹20.50 lakh tax addition based on medical college search documents. Rules third-party material needs corroboration and cross-examination.

Belated Payment of Tribunal Cost Not Fatal to Appeal: ITAT Hyderabad

October 4, 2025 534 Views 0 comment Print

ITAT Hyderabad restores appeal dismissed by CIT(A) due to late payment of Tribunal-directed cost. Rules substantive justice prevails, imposes additional ₹20,000 fine.

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