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JAO-Issued 148 Notice After 29.03.2022 Held Invalid: Entire Reassessment Quashed- Chennai ITAT

December 9, 2025 705 Views 0 comment Print

The ITAT ruled that a Section 148 notice issued by a Jurisdictional AO after 29.03.2022 is invalid because, under the Faceless Reassessment Scheme, only the Faceless Assessing Officer can issue such notices. The entire reassessment was therefore quashed as without jurisdiction.

Addition u/s. 68 towards cash deposit during demonetization unwarranted as genuineness of cash sales proved

December 9, 2025 426 Views 0 comment Print

ITAT Jaipur held that addition towards unexplained cash deposit during demonetization under section 68 without rejection of books of accounts is unwarranted. Further, addition is also not warranted as genuineness of cash sale duly proved.

ITAT Deletes Additions for Alleged Bogus Purchases & Unproved Unsecured Loans

December 9, 2025 696 Views 0 comment Print

The ITAT held that the alleged bogus purchases could not stand when the assessee produced complete documentary evidence showing genuine procurement and consumption. With no contrary evidence from the AO, the 69C addition was removed.

HUF Gift to Member: Why It Should Be Treated as Exempt Under Section 10(2)?

December 9, 2025 1572 Views 0 comment Print

ITAT Kolkata held that addition under section 56(2) towards receipt of gift from HUF to be re-considered for exemption under section 10(2) of the Income Tax Act. Accordingly, matter restored back to AO with specific direction.

Non-Faceless 148 Notice Rule of Law Prevails: JAO-Issued U/s 148 Notice Post-Scheme Declared Void

December 9, 2025 642 Views 0 comment Print

The Tribunal held that once the 29.03.2022 Scheme came into force, only faceless units could issue such notices; a JAO-issued notice was illegal, nullifying the entire reassessment.

Reopening Collapses: 148 Notice by Jurisdictional AO After 29.03.2022 Held Void ab initio

December 9, 2025 1485 Views 0 comment Print

ITAT Chennai ruled that Section 148 notices issued manually by a Jurisdictional AO after 29.03.2022 violate the faceless reassessment procedure. The Tribunal quashed the reassessment order, emphasizing that only NFAC-issued notices are legally valid.

Section 148 Notice by JAO After Faceless Regime? Chennai ITAT Quashes Both Reassessments

December 9, 2025 834 Views 0 comment Print

Arulmigu Vettudaiyar Kaliamman Thirukovil Vs ITO (ITAT Chennai) Assessee challenged reassessment solely on the legal ground that notices u/s 148 dated 31.03.2022 (AY 2015-16) & 29.03.2023 (AY 2016-17) were issued by the Jurisdictional AO (JAO) instead of the Faceless Unit, contrary to Sec.151A & CBDT’s Faceless Reassessment Scheme notified on 29.03.2022, which mandates automated/faceless issuance […]

Faceless Assessment Scheme Mandatory for Section 148 Notices

December 9, 2025 1647 Views 0 comment Print

ITAT Chennai held that a notice issued u/s 148 by the Jurisdictional AO after 29.03.2022 violates the mandatory faceless assessment scheme. Consequently, the reassessment and all subsequent actions, including penalty, were declared null and void.

Entire Derivative Loss Addition Deleted for Lack of Evidence & Reliance on Invalid SEBI Order

December 9, 2025 537 Views 0 comment Print

ITAT Kolkata deletes ₹7.84 crore addition on F&O and currency-derivative losses as AO relied solely on a now-vacated SEBI interim order. Tribunal emphasized that the assessee submitted full documentary evidence, which remained unrebutted, confirming losses as genuine.

Exgratia Provision Sent Back to AO; Double Disallowance on Leave Encashment Deleted

December 9, 2025 354 Views 0 comment Print

Tribunal remands ₹88 lakh disallowance of long-term service award to the AO for fresh verification as employee-wise computation for the relevant year was not on record. Claim can be allowed only after proper quantification of ascertained liability.

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