Income Tax : ITAT Kolkata quashed a reassessment order, holding that NFAC had no jurisdiction before the formal notification of Section 151A. T...
Income Tax : Parasnath Fuels Pvt. Ltd. Vs DCIT (ITAT Dehradun) Rule 29 Rescues Assessee- Loans Need Fresh Look: ITAT Admits New Evidence, Sends...
Income Tax : The Tribunal ruled that additions based on third-party search without giving the assessee a chance to examine evidence violated na...
Income Tax : The Court set aside notices issued manually by the JAO, holding that reassessment and issuance of Section 148 notices must follow ...
Income Tax : The ITAT held that reassessment notices issued without the correct statutory sanction under section 151(ii) are void ab initio, em...
ITAT Kolkata quashed a reassessment order, holding that NFAC had no jurisdiction before the formal notification of Section 151A. The ₹2.14 crore addition was deleted, highlighting that faceless assessments cannot be retroactively enforced.
Parasnath Fuels Pvt. Ltd. Vs DCIT (ITAT Dehradun) Rule 29 Rescues Assessee- Loans Need Fresh Look: ITAT Admits New Evidence, Sends Rs.90 Lakh Addition Back to AO Assessee appealed against NFAC order dated 08.10.2024 sustaining addition of Rs.90,00,000/- u/s 68 r.w.s 115BBE towards unsecured loans from M/s Yogya Shippings Pvt. Ltd. (Rs.50 lakh) & M/s […]
The Tribunal ruled that additions based on third-party search without giving the assessee a chance to examine evidence violated natural justice, deleting ₹2.04 Cr and ₹64.11 Lakh for AY 2018-19 & 2019-20.
The Court set aside notices issued manually by the JAO, holding that reassessment and issuance of Section 148 notices must follow the mandatory faceless mechanism under Section 151A. The ruling reinforces that the JAO has no concurrent jurisdiction.
The ITAT held that reassessment notices issued without the correct statutory sanction under section 151(ii) are void ab initio, emphasizing that procedural compliance is crucial before examining merits of the case.
The Court held that notices under Sections 148A and 148 issued by the JAO were invalid as the faceless procedure mandated by Section 151A was not followed. All impugned notices and orders were quashed.
The High Court ruled that reassessment proceedings were invalid because the notice under Section 148 was issued by the jurisdictional officer instead of through the mandatory faceless mechanism under Section 151A. The Court set aside the notices for non-compliance with statutory procedure.
The Court quashed multiple notices and assessment orders for AY 2018-19, holding that procedural requirements under Section 151A were not met, while preserving Revenue’s right to revive proceedings.
The High Court held that reassessment notices issued by the jurisdictional officer after the faceless regime came into force were without authority. All related proceedings were quashed, and the ITAT appeal was directed to be closed as infructuous.
ITAT quashed reassessment notice issued by Jurisdictional AO instead of Faceless AO. Addition of ₹29.69 crore was invalidated, and Revenue’s appeal became infructuous.
