Income Tax : Budget 2026 introduces sweeping retrospective amendments affecting limitation, reassessment jurisdiction, DIN validity, and TPO ti...
Income Tax : The Tribunal held that the reassessment notice issued on 26.07.2022 was beyond the permissible timeline under the surviving limita...
Income Tax : The Telangana High Court held that reassessment proceedings initiated by the Jurisdictional Assessing Officer after implementation...
Income Tax : The Tribunal held that merely declaring presumptive income under Section 44AD does not exempt taxpayers from explaining massive ba...
Income Tax : The Tribunal held that since the Assessing Officer made no addition after verifying disclosures, the grievance lacked merit. Groun...
Income Tax : The issue was whether reassessment beyond three years is valid for small additions. ITAT held that without meeting the ₹50 lakh ...
The Tribunal held that reopening based on unverified Investigation Wing inputs, factual inconsistencies, and no direct nexus to the assessee’s transactions is invalid. Mechanical reproduction of information cannot sustain reassessment.
Addition of ₹2.28 crore made as long-term capital gains in the hands of the assessee society was deleted in full as amount paid by a developer directly to individual members of a co-operative housing society pursuant to redevelopment cannot be taxed as capital gains in the hands of the society, particularly when the society itself never received the amount.
The ruling declares reassessment void where notices were not issued through the faceless mechanism post-29.03.2022. Lesson: non-compliance with section 151A vitiates reopening.
The case addressed the legality of reopening an assessment when the notice was not issued through NFAC. Following jurisdictional High Court rulings, the Tribunal ruled that such deviation vitiates the entire reassessment process.
The High Court held that notices issued under Section 148 by a jurisdictional Assessing Officer were without authority when the faceless assessment scheme applied. Relying on binding precedents, the writ petition was disposed of in favour of the taxpayer, reaffirming NFAC’s exclusive role.
Gattula Lakshmi Madhavi Vs ACIT (ITAT Visakhapatnam) Central Circle Cannot Assume Reassessment Powers — Section 148 Notice Issued Outside Faceless Regime Held Void The Visakhapatnam Bench of the ITAT quashed the reassessment framed under Section 147 and consequential penalties under Sections 270A and 271AAC in the case of Gattula Lakshmi Madhavi v. ACIT, holding that […]
The case examined whether reassessment proceedings could survive when issued outside the faceless mechanism. The ruling confirms that non-compliance with the faceless scheme is a fatal jurisdictional defect.
The Tribunal held that a bona fide delay caused by genuine circumstances deserves condonation. The key takeaway is that technical limitation cannot override substantive justice.
The Tribunal held that a notice dated 31.03.2021 but dispatched after 01.04.2021 is governed by the new reassessment regime. Failure to follow section 148A procedures rendered the entire reassessment void.
The ITAT Chennai held a reassessment notice under section 148 invalid as it was issued after the statutory limitation expired, emphasizing strict compliance with time limits.
