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 reassessment initiated by a jurisdictional officer after the faceless scheme became mandatory was invalid. The key takeaway is that failure to follow the faceless mechanism nullifies the entire reopening, regardless of merits.
The Tribunal ruled that non-compliance with the faceless reassessment scheme strikes at jurisdiction itself. JAO-issued notices post-notification were held legally unsustainable.
The Tribunal held that reassessment initiated after three years was void as approval was taken from an incompetent authority. The key takeaway is that failure to comply with section 151(ii) invalidates the entire reassessment.
The Tribunal held that after 29-03-2022, only a Faceless Assessing Officer is empowered to issue notices under Section 148. Notices issued by a jurisdictional officer were declared void, vitiating the entire reassessment.
The ITAT held that approval under section 151 by an incompetent authority invalidates reassessment. Sanction must strictly follow statutory hierarchy.
The Tribunal held that notices issued under Section 148 must follow the faceless mechanism prescribed by the CBDT Scheme, 2022. Issuance by the Jurisdictional Assessing Officer instead of the Faceless Assessing Officer vitiated the proceedings.
The Court held that reassessment initiated outside the statutory framework of Section 151A is invalid. All notices and approvals issued by the jurisdictional officer were quashed, with liberty reserved for revival.
The High Court held that reassessment proceedings initiated beyond the scope of Section 151A are void in law. All notices issued under Sections 148 and 142(1) were therefore set aside.
Karnataka High Court invalidated reassessment proceedings and related notices for AY 2015-16, holding that actions initiated beyond Section 151A are legally void.
The ITAT held that a reassessment notice issued by the Jurisdictional AO after 29-03-2022 violated the mandatory faceless reassessment scheme. Such a jurisdictional lapse vitiates the entire proceedings.
