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One-Day Notice Invalidates Reassessment: ITAT Chennai Quashes U/s 148A(b) Proceedings

December 15, 2025 366 Views 0 comment Print

ITAT Chennai held that issuing a notice under Section 148A(b) with only one day to respond violates the statutory minimum of seven clear days. All consequential proceedings, including the 148 notice and reassessment, were quashed as non-est, while substantive additions were left open as academic.

175-Day Delay Condoned by ITAT for Remote Villager Assessee

December 15, 2025 273 Views 0 comment Print

The Tribunal highlighted that non-receipt of assessment notice and lack of knowledge about tax procedures justified the 175-day delay. The appeal was restored to the AO, ensuring the assessee is given proper opportunity to present his case.

ITAT Amritsar Deletes Section 69A Addition on Demonetisation Cash Sales

December 15, 2025 564 Views 0 comment Print

ITAT Amritsar ruled that accepting demonetised currency beyond the permitted date does not ipso facto create unexplained income under Section 69A. The assessee’s cash sales were already included in gross turnover, so no further addition was justified.

ITAT Restores Section 54F Dispute to CIT(A) After Death of Assessee

December 15, 2025 243 Views 0 comment Print

The Tribunal set aside the prior order as the deceased assessee could not represent himself and legal heirs were not on record. CIT(A) is directed to consider all issues afresh, including denial of indexed cost and 54F exemption.

Penalty order u/s. 271D/271E beyond 6 months from assessment is barred by limitation

December 15, 2025 1224 Views 0 comment Print

ITAT Jaipur held that penalty orders under section 271D and 271E of the Income Tax Act passed beyond 6 months from end of the month in which assessments were completed is barred by limitation. Accordingly, appeal of revenue stands dismissed.

ITAT Confirms U/s 263 Revision for Unexamined U/s 80G Donation

December 15, 2025 753 Views 0 comment Print

The ITAT held that the AO’s allowance of an 80G deduction without examining the background of M/s. Aadhar Foundation was erroneous. The decision reinforces that Explanation-2 to Section 263 requires verification when there is material indicating possible bogus donations.

Revision proceeding u/s. 263 quashed as AO has taken plausible view

December 15, 2025 393 Views 0 comment Print

ITAT Hyderabad held that invocation of revisionary jurisdiction under section 263 of the Income Tax Act unsustainable since AO has taken plausible view. Accordingly, assessment order is neither erroneous nor prejudicial hence revision order quashed.

Amended Reassessment Provisions Cannot Reopen Years Already Barred Under Old Law

December 15, 2025 1509 Views 0 comment Print

The Tribunal ruled that the amended reassessment law does not revive assessment years that had become time-barred under the earlier statutory provisions.

Full Section 54F Exemption Allowed for Joint Purchase Where Assessee Funded Entire Cost: ITAT Jaipur

December 15, 2025 1146 Views 0 comment Print

The ITAT Jaipur held that joint ownership of a new property does not bar full exemption under Section 54F if the assessee funds the purchase and retains control over the asset.

No Section 271(1)(c) Penalty for Unsubstantiated Portion of Section 54F Deduction: ITAT Chennai

December 15, 2025 414 Views 0 comment Print

The Tribunal ruled that partial disallowance of section 54F deduction, without concealment or inaccurate particulars, does not warrant penalty under section 271(1)(c).

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