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...
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.
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.
