Income Tax : Budget 2026 introduces sweeping retrospective amendments affecting limitation, reassessment jurisdiction, DIN validity, and TPO ti...
Income Tax : The issue was whether addition can be made based on third-party investigation findings. The Tribunal held that without direct incr...
Income Tax : The Tribunal held that reopening beyond three years requires escaped income in the form of an asset. Since bogus purchases are rev...
Income Tax : The Tribunal held that dividend received from identifiable mutual funds through banking channels cannot be treated as unexplained ...
Income Tax : ITAT Mumbai held that long-term capital gains from share sales cannot be treated as unexplained cash credit when the assessee prov...
Income Tax : The Tribunal ruled that Section 148A(b) requires a minimum of seven days for the assessee to respond. Failure to grant this statut...
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.
The Tribunal quashed reassessment proceedings where the section 148 notice and section 148A(d) order were issued by the JAO instead of the FAO. It reaffirmed that post-notification violations of the faceless scheme cannot be cured by participation or waiver.
The ITAT held that reassessment notices issued by a JAO after 29.03.2022 are void, as only a Faceless Assessing Officer can act under the faceless regime.
The Tribunal held that CSR contributions received with strict donor directions and refund obligations may constitute tied-up grants rather than freely available income. Such funds require factual examination before taxing them under section 11.
The Tribunal held that a notice issued under section 148 on 31.07.2022 for AY 2014-15 was barred by limitation under the amended section 149. Reassessment proceedings were quashed as void ab initio.
Applying a liberal approach, the tribunal condoned delay in appeal filing and examined the jurisdictional defect. Since reopening was initiated by the wrong authority, the assessment could not survive.
ITAT ruled that an appeal cannot be rejected mechanically on alleged defects when records show compliance. The case was remanded for fresh, reasoned adjudication after proper hearing.
Chennai ITAT held that reassessment notices issued by a JAO after 29-03-2022 are invalid under the mandatory faceless assessment framework, quashing all consequential orders while preserving the Revenue’s right to revive proceedings if Apex Court rules otherwise.
