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ITAT Hyderabad

When no addition on reopening issue, entire 147 proceeding falls JAO had no jurisdiction post-Faceless Scheme

October 10, 2025 1155 Views 0 comment Print

ITAT Hyderabad in Pitti Holdings Pvt. Ltd. vs ACIT quashes a reassessment for the Assessment Year 2018-19. The order holds that notices issued by the Jurisdictional AO (JAO) instead of the Faceless AO (FAO) after the Faceless Jurisdiction Scheme 2022 are void ab initio.

Faceless means faceless – ITAT Hyderabad quashes reassessment by local AO as void- JAO had no power post-2022 Scheme

October 10, 2025 831 Views 0 comment Print

The ITAT Hyderabad ruled that reassessment notices under Sections 148A(b) and 148 issued by the Jurisdictional Assessing Officer (JAO) after April 1, 2022, are invalid and void ab initio. This decision reinforces the mandatory nature of the Faceless Jurisdiction Scheme, 2022, quashing the entire reassessment for lack of proper authority.

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

October 4, 2025 720 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.

Order passed by AO in old PAN cannot be survived if transactions already reported in new PAN

September 30, 2025 597 Views 0 comment Print

ITAT Hyderabad held that assessment order passed by AO in old PAN cannot be survived if transactions reported by DGFT in old PAN is already reported by assessee in new PAN. Accordingly, matter restored back to re-verify.

Deletion of addition u/s. 69A by CIT(A) is contrary to material on record: AO directed to reconsider

September 26, 2025 462 Views 0 comment Print

ITAT Hyderabad held that reasoning given by CIT(A) for deletion of addition made u/s. 69A of the Income Tax Act by Assessing Officer towards cash payment is contrary to material on record and cannot be accepted.

Laptop Data Alone Cannot Justify Reopening u/s 148: Excel Sheets Not Books or Assets

September 25, 2025 999 Views 0 comment Print

ITAT Hyderabad rules Excel sheets from an accountant’s laptop aren’t ‘books’ or ‘assets,’ quashing reassessment notices against Exel Rubber for mechanical sanction and insufficient evidence.

No Capital Gains on Mere Joint Development Agreement Without Possession: ITAT Hyderabad

September 25, 2025 2553 Views 0 comment Print

ITAT Hyderabad ruled that a Joint Development Agreement (JDA) doesn’t trigger Capital Gains Tax u/s 2(47)(v) when possession isn’t legally delivered, relying on SC/HC precedent.

ITAT Rejects Arbitrary Transfer Pricing Adjustments on Management Services

September 25, 2025 474 Views 0 comment Print

ITAT Hyderabad deletes a ₹10.10 Cr TP adjustment on AE consultancy fees to Virinchi Ltd, holding TPO cannot question commercial expediency of services when ALP is proven.

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