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.
Tribunal observed that AO accepted returned income without any independent examination or inquiry. As major issues like estimation of profit in liquor trade and tax audit requirements were ignored, assessment was held erroneous. Pr. CIT’s revision under Section 263 was sustained.
ITAT set aside ex-parte additions for unsecured loans and partner’s capital, ruling that taxpayer had reasonable cause for late submission of evidence due to departure of their accountant and Authorized Representative (AR). Tribunal directed CIT(A) to admit evidence under Rule 46A and decide case on its merits.
Tribunal reversed disallowance of Section 80P deduction, affirming that interest income earned by a co-operative society from deposits with a co-operative bank is eligible for tax benefit.
ITAT ruled that a resident individual, opting for new tax regime with income below ₹7 lakhs, is eligible for full S 87A rebate, even if their income includes STCG under S 111A3 Court held that no statutory bar existed for Assessment Year 2024-25, invalidating system-driven denial by CPC.
