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Ex-Parte Appeal Dismissal Set Aside for Lack of Reasoned Order

January 16, 2026 351 Views 0 comment Print

The issue was whether the appellate authority could dismiss an appeal ex-parte without giving detailed reasons. The Tribunal held that a non-speaking order violates section 250(6) and restored the appeal for fresh adjudication.

Reassessment Quashed as JAO Lacked Jurisdiction After Faceless Scheme

January 16, 2026 1938 Views 0 comment Print

The issue was whether reassessment notices could be issued by a jurisdictional officer after the faceless reassessment scheme became mandatory. The Tribunal held that such notices are void, rendering the entire reassessment unsustainable.

Appeal Dismissed on Delay Remanded for Merits Despite Non-Compliance

January 16, 2026 1014 Views 0 comment Print

The issue was whether an appeal involving large additions could be dismissed solely for delay without examining merits. The Tribunal held that technical dismissal was improper and ordered remand with costs. Key takeaway: meritorious matters should be decided on merits, not limitation alone.

Accepted Closing Cash Cannot Be Treated as Unexplained Income

January 16, 2026 285 Views 0 comment Print

The Tribunal held that once a closing cash balance is disclosed and accepted in a prior year’s scrutiny assessment, it cannot be questioned as unexplained opening cash in a subsequent year.

Reassessment Quashed for Issuance of Notice Outside Faceless Regime

January 16, 2026 1818 Views 0 comment Print

The issue was whether reassessment could be initiated by a jurisdictional officer after faceless schemes became mandatory. The Tribunal held that notices issued outside the faceless mechanism lack jurisdiction and invalidate the reassessment.

Reopening After 3 Years Invalid If Escapement Is Below ₹50 Lakh

January 16, 2026 1530 Views 0 comment Print

Sanjay Champalal Jaiswal Vs ITO (ITAT Pune) Reopening Beyond Three Years Invalid Where Escapement Is Below ₹50 Lakh — ITAT Pune Quashes Reassessment The Pune SMC Bench of the ITAT quashed the reassessment for AY 2016-17, holding that the notice under section 148 dated 27-07-2022 was without jurisdiction, as the alleged income escaping assessment was […]

Section 263 Validly Invoked for Allowing Section 80P in Belated Return

January 16, 2026 615 Views 0 comment Print

The issue was whether deduction under section 80P could be allowed when the return was filed beyond the due date. The Tribunal held that non-compliance with section 80AC made the assessment erroneous, justifying revision under section 263.

Capital Gains Recomputed After Proving Gift-Funded Purchase Cost

January 16, 2026 579 Views 0 comment Print

The dispute concerned denial of property purchase cost where payments were made by a close relative. The Tribunal held that once source and utilization of funds are established, such payments must be allowed as cost of acquisition. Key takeaway

Reopening Invalid When Search Material Triggers Section 153C

January 16, 2026 1137 Views 0 comment Print

The Tribunal held that when reassessment is based on material found during a third-party search, proceedings must be initiated under Section 153C and not Section 147. Reopening under Section 147 was therefore without jurisdiction and liable to be quashed.

Ex-parte Assessment Diluted: ITAT Indore Upholds CIT(A)’s Relief in Kriti Nutrients Case

January 16, 2026 396 Views 0 comment Print

The issue was whether rejection of books and enhancement of gross profit were justified due to alleged non-compliance. The Tribunal upheld partial relief, holding that GP estimation must be reasonable and supported by facts, not solely by procedural lapses.

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