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 court held that a reassessment notice issued by the jurisdictional officer violated the faceless assessment scheme. As a result, the notice and the consequential assessment order were set aside, subject to liberty if higher courts take a different view.
ITAT Hyderabad held that issuance of notice under section 148 of the Income Tax Act by Jurisdictional Assessing Officer, post introduction of ‘Faceless Jurisdiction of Income tax Authorities Scheme, 2022, is bad and illegal in law. Accordingly, order passed thereon is quashed and set aside.
The High Court held that reassessment proceedings initiated by a jurisdictional Assessing Officer were without authority after introduction of the faceless scheme. All notices, assessment orders, and demands were set aside on jurisdictional grounds.
The Tribunal held that receipts already offered under the presumptive scheme cannot be taxed again as unexplained money. Once income is declared under section 44AD and supported by surrounding facts, section 69A has no application.
The issue was whether the appellate authority could bypass jurisdictional objections by remanding the case. The tribunal held that legal grounds striking at jurisdiction must be adjudicated first.
The Tribunal held that additions based solely on third-party GST information and suspicion cannot be sustained without independent investigation, restricting estimation to 1% of sales.
The Tribunal held that reassessment notices issued by the Jurisdictional AO after the faceless regime came into force are invalid. The key takeaway is that only faceless authorities can initiate reassessment post-29 March 2022.
The issue was whether reassessment initiated by the Jurisdictional AO was valid. The Tribunal held the notice invalid as it violated mandatory faceless assessment procedures, rendering the reassessment void.
The Tribunal held that NFAC had no authority to pass reassessment orders before the faceless reassessment notification became operative. As a result, the entire assessment was quashed. The ruling highlights that participation by the assessee cannot cure jurisdictional defects.
The Tribunal held that a general survey admission by the seller cannot justify additions in every buyers case. Documentary proof of purchases and sales outweighed unsupported allegations.