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The reassessment notice under Section 148 issued after 01.04.2021 did not comply with the amended provisions requiring enquiry and hearing. The NFAC held the reassessment order void ab initio. This ruling emphasizes strict adherence to procedural safeguards under amended law.
Tribunal holds that reassessment proceedings under Sections 147/148 are invalid as the notice was issued beyond the extended due date, following Supreme Court guidance in Rajeev Bansal.
The Tribunal held that reassessment proceedings initiated without a properly signed Section 151 approval are invalid. The notice under Section 148 was quashed, and the assessee’s appeal was allowed.
Tribunal deleted protective additions after finding no corresponding substantive assessment. The ruling clarifies that protective action cannot stand alone under Sections 147/143(3).
The Tribunal ruled that once the assessee responds to a 148A(b) notice, the AO must complete the 148A(d)–148 cycle within the remaining time. In this case, the notice overshot the surviving limitation period, making reassessment legally defective. Consequently, all additions related to alleged accommodation entries and loans were quashed.
Tribunal quashed reopening under Section 147 where AO’s presumption of non-filing contradicted the documented return, citing Deepak Wadhwa precedent.
The Tribunal held that reassessment under Sections 147/143(3) is invalid without a Section 143(2) notice. It ruled that using the return filed under Section 148 triggers the mandatory requirement.
Delhi HC ruled that both jurisdictional and faceless officers can issue Section 148 notices. It reaffirmed that faceless regime does not eliminate JAO authority until Supreme Court decides otherwise.
Assessee succeeded in cross-objection as reassessment lacked jurisdiction and Section 69C addition was inapplicable, confirming deletion of addition and quashing proceedings.
Tribunal held that assessment was void because no notice under Section 143(2) was issued, confirming that such omission cannot be cured and invalidates entire assessment.
