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Tribunal accepted the assessee’s explanation for delay and held that denial of opportunity justified remand for fresh assessment under Section 147/144B.
Tribunal found that the CIT(A) admitted new evidence without AO’s opportunity and remanded the case for re-examination of NRE deposit sources under Section 69.
The Tribunal held that CIT(A) must decide all grounds, including legality of reopening under Section 147/148. Order remanded for fresh adjudication under Section 250(6).
Gujarat High Court held that PAN jurisdiction in ITBA [Income Tax Business Application] portal is of no consequence in absence of order passed under section 127 of the Income Tax Act. Accordingly, notice and order thereof is liable to be quashed.
ITAT ruled that reassessment under section 147 is valid even if based on an old PAN, as banking and TDS records may reflect its continued use. Ex parte assessment was remanded for proper reconciliation.
Reassessment proceedings initiated without obtaining prior approval from the appropriate “specified authority” under Section 151(ii) such as the Principal Chief Commissioner of Income Tax or the Principal Director General were invalid.
ITAT Mumbai ruled that once the Assessing Officer is aware of a merger, assessment in the name of the amalgamating company is invalid and without jurisdiction.
The Madras High Court upheld a reassessment order passed under Section 144 after the taxpayer failed to respond to Section 148 notices. The Court found no reason to interfere but permitted an appeal within 30 days.
ITAT Mumbai held that doubting goods transportation alone cannot justify full disallowance, restricting the addition to 11.54% GP on ₹32.75 lakh purchases.
ITAT Delhi invalidated a reassessment under Sections 144/147, citing mechanical approval by authorities and incorrect statutory references. The ruling reinforces that higher authorities must apply proper legal mind when granting sanction under Section 151.