The ITAT held that issuance of Section 148 notice by a Jurisdictional Assessing Officer instead of a Faceless Assessing Officer violates Section 151A, leading to quashing of the reassessment.
The Tribunal dismissed the income tax appeal after the assessee formally requested withdrawal. The ruling confirms that appeals may be closed when the assessee opts not to pursue them.
The Tribunal directed fresh examination of whether the government allocation received by the assessee constituted a corpus fund under section 11(1)(d). It held that the lower authorities had not properly considered the assessee’s submissions, requiring the matter to be verified afresh.
The Tribunal held that the appeal should be heard on merits after the CIT(A) dismissed it solely for a 45-day delay. It restored the matter for fresh adjudication, directing that the delay issue not be reconsidered.
The Tribunal remanded the sustained cash deposit addition after accepting additional evidence. It directed the CIT(A) to reconsider the ₹7.02 lakh addition through de novo adjudication.
The Tribunal held that the AO’s rejection of books under Section 145(3) was unsustainable as no specific defects were identified. The ruling confirms that estimation of income cannot be based on assumptions when records are supported by documentation.
The Tribunal held that the Section 148 notice issued by the jurisdictional officer instead of the faceless authority violated Section 151A. With the notice invalid, the reassessment and jewellery addition were quashed.
The ITAT concluded that non-compliance with faceless procedure under Section 151A renders Section 148 notices invalid, nullifying both substantive and protective additions.
ITAT Chandigarh deleted ₹38.70 Lakh addition as unexplained expenditure, holding that fully bank-routed agricultural expenses cannot be disallowed merely due to missing bills. The Tribunal confirmed that legitimate orchard expenses on labor, fertilizers, and packing are deductible from agricultural income.
Tribunal directs AO to apply the 30% tax rate on unexplained cash deposits during Nov–Dec 2016, citing Madras High Court ruling, partially allowing assessee’s appeal.
