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The ITAT held that reassessment notices under section 148 issued to a deceased person are invalid, emphasizing that such notices cannot confer jurisdiction and proceedings are void ab initio.
Tribunal held that additions made solely on ex-parte proceedings cannot stand when the taxpayer was unable to comply due to age-related limitations. The case was remanded for fresh assessment with a direction to provide proper opportunity.
The ITAT annulled the entire reassessment because the Section 148 notice was issued after the Supreme Court–mandated surviving-period cutoff. The ruling confirms that any notice beyond this timeline is void ab initio.
Tribunal clarified that mere generation or digital signing on ITBA does not mean a notice is issued. Proper dispatch to the assessee’s email or portal before the statutory deadline is required for validity.
ITAT held that a 147 reopening based on the incorrect assumption that no return was filed is invalid. Since the assessee proved the return was filed, the entire reassessment was quashed.
The Tribunal ruled that reopening based solely on an Insight Portal flag without independent verification is invalid. It held that absence of tangible material and incorrect factual assumptions renders the entire 147 proceeding void.
ITAT held that reassessment notices issued beyond three years require approval from PCCIT/PDGIT, not PCIT. The invalid sanction vitiated all proceedings, following Rajeev Bansal.
ITAT held that reassessment based solely on earlier-examined facts is invalid. Since shares were sold through a SEBI broker and gains were already taxed, no Section 68 addition could survive.
The Tribunal held that the assessee failed to show sufficient cause for a long delay, noting negligence and absence of due care. late appeals require concrete justification, not assumptions or later legal advice.
The Tribunal observed that additions forming the basis of the penalty had not yet attained finality before the first appellate authority. It therefore restored the matter to the Assessing Officer for reconsideration after completion of the quantum appeal.
