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Section 151A

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Retrospective Amendments under Budget 2026 – Rectification, Revision, Reassessment Options before Tax Authorities

Income Tax : Budget 2026 introduces sweeping retrospective amendments affecting limitation, reassessment jurisdiction, DIN validity, and TPO ti...

February 26, 2026 6297 Views 1 comment Print


Latest Judiciary


ITAT Pune Set Aside Section 69A Addition as Reopening Notice Was Time Barred

Income Tax : The Tribunal held that the reassessment notice issued on 26.07.2022 was beyond the permissible timeline under the surviving limita...

May 21, 2026 333 Views 0 comment Print

Telangana HC Quashes Reassessment by Jurisdictional AOs After Faceless Scheme Implementation

Income Tax : The Telangana High Court held that reassessment proceedings initiated by the Jurisdictional Assessing Officer after implementation...

May 20, 2026 186 Views 0 comment Print

Goat Trader Fails to Explain ₹7.10 Crore Bank Deposits: ITAT Upholds Section 69A Addition Despite U/s 44AD Claim

Income Tax : The Tribunal held that merely declaring presumptive income under Section 44AD does not exempt taxpayers from explaining massive ba...

May 18, 2026 312 Views 0 comment Print

ITAT Rejects Appeal Where Declared Capital Gains Accepted Without Adjustment

Income Tax : The Tribunal held that since the Assessing Officer made no addition after verifying disclosures, the grievance lacked merit. Groun...

April 29, 2026 429 Views 0 comment Print

ITAT Mumbai: Reopening Beyond 3 Years Invalid – ₹6 Lakh Escapement Fails ₹50 Lakh Threshold

Income Tax : The issue was whether reassessment beyond three years is valid for small additions. ITAT held that without meeting the ₹50 lakh ...

April 27, 2026 441 Views 0 comment Print


Post-2022 Reassessment Fails for Non-Compliance with Faceless Scheme

December 31, 2025 549 Views 0 comment Print

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.

JAO Can’t Reopen After Faceless Regime: ITAT Hyderabad Quashes s.148 Notices in 4 Appeals

December 31, 2025 462 Views 0 comment Print

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.

CSR Grants Are Tied-Up Funds, Not Free Income of Charitable Trust

December 30, 2025 489 Views 0 comment Print

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.

New Reassessment Law Overrides Old Limitation Extensions

December 30, 2025 708 Views 0 comment Print

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.

Reopening Notice by JAO Invalid After Faceless Scheme

December 30, 2025 531 Views 0 comment Print

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.

NFAC Order Quashed for Casual and Non-Application of Mind

December 29, 2025 252 Views 0 comment Print

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.

Notice by JAO After Faceless Scheme Invalid: Chennai ITAT Quashes Reassessment

December 28, 2025 807 Views 0 comment Print

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.

Faceless Reassessment Is Mandatory: Chennai ITAT Sets Aside 69A Addition Despite Cash Deposits

December 26, 2025 2733 Views 0 comment Print

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.

JAO-Issued Section 148 Notice Held Void Under Faceless Scheme

December 26, 2025 696 Views 0 comment Print

The Tribunal ruled that non-compliance with the faceless reassessment scheme strikes at jurisdiction itself. JAO-issued notices post-notification were held legally unsustainable.

Reopening Beyond Three Years Invalid Without PCCIT Approval: ITAT Amritsar

December 25, 2025 618 Views 0 comment Print

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.

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