The Tribunal held that reassessment notices issued by the jurisdictional officer violated the mandatory faceless regime under Sections 144B and 151A. Non-compliance with the prescribed faceless procedure renders the entire reassessment void ab initio.
The issue was whether Section 153C proceedings for seven years could rest on a single satisfaction note. ITAT held that absence of year-wise satisfaction vitiates jurisdiction, quashing all assessments.
The ITAT held that an unsigned and unexecuted seized agreement cannot establish receipt of cash. The key takeaway is that additions under Section 69A require proof of actual receipt, not mere allegations.
The issue was whether reassessment notices issued by the Jurisdictional AO were valid after the faceless regime. ITAT held that post-notification, only the Faceless AO could act, rendering the reassessment void.
The Tribunal held that delayed responses to statutory notices do not attract penalty when full compliance is ultimately made and accepted before assessment completion. The key takeaway is that penalties cannot be imposed mechanically in the absence of willful default.
Tribunal held that cash found and seized cannot be treated as unexplained when it is fully reflected in audited books and not disproved by tax authority. Additions under Section 69A cannot rest on suspicion alone.
ITAT Hyderabad held that final assessment order passed under section 143(3) of the Income Tax Act by AO beyond the time limit provided under Section 153(1) of the Income Tax Act is barred by limitation. Accordingly, appeal of assessee allowed.
The Tribunal held that interest on income-tax refund is taxable in the year of receipt and qualifies for Section 80-IA deduction, regardless of the year to which the refund relates.
The Tribunal held that cash deposited in demonetised notes cannot be taxed under Section 69A when it represents recorded business sales. The key takeaway is that duly accounted turnover cannot be treated as unexplained merely due to demonetisation.
ITAT Hyderabad held that notices under Section 148 issued on 01.04.2021 without following mandatory Section 148A procedures are invalid. The Tribunal quashed reassessment orders, emphasizing that procedural compliance is jurisdictional and essential.
