Once the Central Government notified the Faceless Scheme for reassessment (effective March 29, 2022), the JAO was effectively divested of the power to issue notices under Section 148. The issuance of a notice by a JAO instead of the National Faceless Assessment Centre (NFAC) was a jurisdictional error that could not be cured.
PCIT s revision under section 263 against assessee was upheld holding that AO did not properly verify the very low Section 14A disallowance despite huge exempt income and also ignored INSIGHT portal inputs about alleged accommodation entries.
The Appellate Authority held that it cannot condone delay beyond the 30-day extended period prescribed under Section 100(2) of the CGST Act. As the appeal was filed 250 days after communication of the AAR order, it was dismissed without examining merits.
The Tribunal held that once satisfaction is recorded under Section 153C, assessment for covered years must proceed strictly under that provision. Framing assessment under Section 143(3) was declared jurisdictionally invalid and quashed.
The Tribunal held that once depreciation on goodwill is allowed in the first year, it cannot be questioned in subsequent years. Revisional powers under Section 263 were found to be wrongly invoked.
The ITAT held that an assessment and appellate order passed without effective participation, allegedly due to notices sent to a wrong email address, must be set aside and remanded for fresh adjudication.
Holding that responsibility for delay required factual adjudication, the High Court refused to exercise writ jurisdiction and relegated the parties to civil or arbitral remedies.
The Court ruled that GST proceedings initiated under Section 74 for FY 2024–25 were without jurisdiction and directed treatment of the order as a Section 74A notice.
The Court held that reimbursement claims cannot be processed without required documents and ordered verification before releasing incentives. Authorities were directed to act within a fixed timeframe if documents are on record.
The High Court held that a reassessment notice issued after expiry of the six-year period under the old regime is barred by limitation. The ruling reiterates that extended timelines under the new law cannot revive time-barred cases.
