Income Tax : Budget 2026 introduces sweeping retrospective amendments affecting limitation, reassessment jurisdiction, DIN validity, and TPO ti...
Income Tax : ITAT Kolkata quashed NFAC reassessment and consequential penalty, holding faceless reassessment lacked jurisdiction before Section...
Income Tax : ITAT Delhi deleted bogus purchase additions, holding that genuine purchases and sales were supported by documentary evidence and t...
Income Tax : ITAT Mumbai quashed reassessment for approval under Section 151(ii) by the wrong authority and deleted penalties under Sections 27...
Income Tax : ITAT Delhi held that a Section 148 notice issued beyond three years is void when sanctioned by the PCIT instead of the authority p...
Income Tax : The ITAT Bangalore held that cash deposits could not be treated as unexplained where they were sourced from earlier withdrawals fr...
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 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.
