Karnataka High Court held that a reassessment notice issued on 7 May 2024 for AY 2017–18 was beyond six-year limitation period under Section 149 of Income Tax Act and therefore invalid.
ITAT Chennai set aside the rejection of an 80G registration application, holding that the prescribed timelines are directory, not mandatory. The Tribunal directed the CIT(E) to process the delayed application on its merits under the amended law.
ribunal held that a delayed application filed after the CBDT deadline could be treated as filed under the new clause (iv)(B) of Section 80G(5), introduced by the Finance Act, 2024. The matter was remanded to CIT(E) for reconsideration.
GSTAT upheld DGAP’s findings that residual ITC benefit of ₹3.55 lakh was passed on by contractor to IOCL, closing anti-profiteering proceedings under Section 171.
The Karnataka High Court quashed the entire chain of faceless reassessment proceedings, including Section 148A, Section 147, and penalty orders. The ruling was based on the reason that the notices were issued by the jurisdictional AO outside the mandatory procedure of Section 151A (Faceless Assessment Scheme). The key takeaway is the non-compliance with the statutory mechanism for faceless proceedings invalidates the entire reassessment.
The Karnataka High Court ruled that reassessment under Section 153A is invalid when no incriminating material is found during a search. The Court held that conversion of a firm into a company, fulfilling Section 47(xiii) conditions, is not taxable as a transfer.
Despite a significant delay, the ITAT Pune condoned the delay in filing the appeal, citing a justice-oriented approach and the assessee’s later knowledge of the ₹25 Lakh leave encashment exemption notification. The case was sent back to the CIT(A) for fresh adjudication to apply the enhanced limit and related case law, highlighting the precedence of justice in appeal delays.
ITAT Chennai held that when sales are accepted and supported by records, entire purchases cannot be treated as bogus merely because suppliers were untraceable. Addition restricted to 12.5% as profit element.
ITAT Mumbai ruled that relief under the first proviso to Section 201(1) is available if Form 26A certifying the deductee’s tax payment is furnished. As the buyer obtained the certificate post-appeal, the case was remanded for verification.
ITAT quashed a reassessment, ruling that S 148 notice was invalid because it was issued before AO formally received mandatory sanction from PCIT under S 151. Relying on Supreme Court, Tribunal held that internal approval is insufficient; communication of sanction to AO is a jurisdictional prerequisite.
