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JAO-Issued Section 148 Notice Invalid: ITAT Chennai Quashes Reassessment

December 9, 2025 588 Views 0 comment Print

Chennai ITAT ruled that a 148 notice issued by JAO post-CBDT faceless scheme notification is invalid, quashing reassessment and penalty. The tribunal confirmed that only notices issued by the Faceless Assessment Unit are legally valid.

Section 148 Notice By JAO Post-Faceless Scheme Vitiates Reassessment

December 9, 2025 918 Views 0 comment Print

ITAT Chennai annulled the Section 148-based reassessment for AY 2018-19 because the notice contravened the e-assessment scheme under Sec.151A. The ruling reinforces mandatory compliance with faceless notice issuance.

Section 148 Assessment Set Aside Over Jurisdiction & DIN Defects

December 9, 2025 993 Views 0 comment Print

ITAT Pune held that the CIT(A) failed to adjudicate key legal grounds, including wrong AO jurisdiction and missing Document Identification Number. Entire order under Section 144 r.w.s. 263 was set aside for reconsideration with proper hearing.

JAO-Issued 148 Notice After 29.03.2022 Held Invalid: Entire Reassessment Quashed- Chennai ITAT

December 9, 2025 741 Views 0 comment Print

The ITAT ruled that a Section 148 notice issued by a Jurisdictional AO after 29.03.2022 is invalid because, under the Faceless Reassessment Scheme, only the Faceless Assessing Officer can issue such notices. The entire reassessment was therefore quashed as without jurisdiction.

Addition u/s. 68 towards cash deposit during demonetization unwarranted as genuineness of cash sales proved

December 9, 2025 468 Views 0 comment Print

ITAT Jaipur held that addition towards unexplained cash deposit during demonetization under section 68 without rejection of books of accounts is unwarranted. Further, addition is also not warranted as genuineness of cash sale duly proved.

ITAT Deletes Additions for Alleged Bogus Purchases & Unproved Unsecured Loans

December 9, 2025 720 Views 0 comment Print

The ITAT held that the alleged bogus purchases could not stand when the assessee produced complete documentary evidence showing genuine procurement and consumption. With no contrary evidence from the AO, the 69C addition was removed.

HUF Gift to Member: Why It Should Be Treated as Exempt Under Section 10(2)?

December 9, 2025 1617 Views 0 comment Print

ITAT Kolkata held that addition under section 56(2) towards receipt of gift from HUF to be re-considered for exemption under section 10(2) of the Income Tax Act. Accordingly, matter restored back to AO with specific direction.

Non-Faceless 148 Notice Rule of Law Prevails: JAO-Issued U/s 148 Notice Post-Scheme Declared Void

December 9, 2025 678 Views 0 comment Print

The Tribunal held that once the 29.03.2022 Scheme came into force, only faceless units could issue such notices; a JAO-issued notice was illegal, nullifying the entire reassessment.

Reopening Collapses: 148 Notice by Jurisdictional AO After 29.03.2022 Held Void ab initio

December 9, 2025 1515 Views 0 comment Print

ITAT Chennai ruled that Section 148 notices issued manually by a Jurisdictional AO after 29.03.2022 violate the faceless reassessment procedure. The Tribunal quashed the reassessment order, emphasizing that only NFAC-issued notices are legally valid.

Section 148 Notice by JAO After Faceless Regime? Chennai ITAT Quashes Both Reassessments

December 9, 2025 870 Views 0 comment Print

Arulmigu Vettudaiyar Kaliamman Thirukovil Vs ITO (ITAT Chennai) Assessee challenged reassessment solely on the legal ground that notices u/s 148 dated 31.03.2022 (AY 2015-16) & 29.03.2023 (AY 2016-17) were issued by the Jurisdictional AO (JAO) instead of the Faceless Unit, contrary to Sec.151A & CBDT’s Faceless Reassessment Scheme notified on 29.03.2022, which mandates automated/faceless issuance […]

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