The Court set aside notices issued manually by the JAO, holding that reassessment and issuance of Section 148 notices must follow the mandatory faceless mechanism under Section 151A. The ruling reinforces that the JAO has no concurrent jurisdiction.
The Court held that an appeal cannot be dismissed for pre-deposit deficiency without prior notice or opportunity to cure the defect. The matter was remanded for fresh consideration on merits.
Aseem Sehgal Vs ITO (ITAT Delhi) The appeals concern assessment years 2015–16 to 2017–18 and arise from reassessment orders issued under Sections 147 and 144B of the Income-tax Act. The sole issue examined by the Tribunal is whether the Assessing Officer was justified in framing reassessment under the pre-April 2021 provisions despite issuing the notice […]
The Tribunal held that once the assessee provided prima facie evidence of identity, creditworthiness, and genuineness, the burden shifts to the AO to make independent inquiries. Non-compliance renders additions invalid.
ITAT Surat relied on precedents (Hari Gopal, Marksans Pharma, Boparai P. Ltd.) to hold that ad-hoc or percentage-based additions do not trigger Section 271(1)(c) penalty. Appeal allowed, penalty deleted.
The ITAT Pune remanded a case where the first appellate authority dismissed an appeal ex-parte. taxpayers must be given a fair hearing before dismissal, reinforcing the principle of natural justice.
SC ordered Department to comply with High Court directions and issue C-Forms and F-Forms after verification of indemnity bonds, leaving legal questions open for future cases.
The High Court set aside a GST appellate order after finding that it lacked reasoning and failed to address the taxpayer’s ITC claim made in GSTR-9. The matter was remanded for fresh consideration.
CIT(A) set aside penalties imposed for violations of Sections 269SS and 269T, as they were issued beyond the statutory limitation period. The ruling reaffirms that late penalty orders are invalid even if violations occurred.
Appeal delayed by 252 days due to counsel’s oversight was condoned by ITAT citing reasonable diligence. Tribunal then reduced unexplained cash addition under Section 69A to ₹1.8 lakh using a fair estimation method.
