Karnataka High Court quashed reassessment notices and orders for AY 2020-21, ruling they were issued without proper statutory jurisdiction under the framework of Section 151A. The ruling reinforces that procedural non-compliance in the faceless scheme voids the notices, while granting Revenue liberty to revive the case post-Supreme Court verdict.
The High Court allowed the petition, ruling that the reassessment proceedings were initiated without jurisdiction because they contravened the procedural requirements of Sec. 151A of the Income Tax Act. This key takeaway reiterates the requirement for strict procedural adherence in the faceless regime, while preserving the Revenues right to revive the case post-Apex Court clarity.
The High Court found no mistake apparent on record to warrant rectification under Section 254, holding that the Tribunal’s decision to uphold the Section 80JJA deduction was neither perverse nor erroneous. The ruling clarifies that Section 254 cannot be used to re-argue the quantum or correctness of a deduction, especially one accepted historically.
Delhi ITAT ruled that a single, non-speaking approval u/s 153D issued for 14 assessment years and two assessees was invalid, holding that approval must be year-specific and assessee-specific. All assessments were quashed as void ab initio.
Karnataka High Court affirmed the ITATs decision, ruling that 81 appellate orders passed by the CIT(A)-11 after the DGIT (Investigation) had explicitly directed him not to pass further orders were without jurisdiction. The key takeaway is that such orders, passed in defiance of supervisory administrative restraint, are illegal and must be reheard de novo by a competent authority.
The Delhi ITAT invalidated a reassessment, ruling the AO failed to establish independent ‘reason to believe’ and merely borrowed satisfaction from an Investigation Wing report without tangible material or a live link to the assessee’s income. This judgment establishes that reassessment cannot be based solely on second-hand, non-incriminating information from a third-party search.
in a colourful observation, the Tribunal compared Juniper’s interlinked trading and service activities to the egg-or-chicken story, holding entity-level TNMM appropriate and deleting the TP addition.
ITAT Delhi set aside a non-speaking order by CIT(A) in a ₹34.82 lakh bogus purchase case, directing de novo adjudication and allowing cross-examination on alleged accommodation entries.
Gurushree Minerals Pvt. Ltd Vs DCIT (Appellate Tribunal Under Safema At New Delhi) Loan or Land Grab?- Benami Land Purchase through Driver – Tribunal Calls Gurushree Minerals’ Deal a Benami Ruse- Tribunal Confirms Attachment of 30.6 Hectares of Tribal Land Bought by Company The Appellate Tribunal under SAFEMA, New Delhi, vide Final Order dt. 14.10.2025 in […]
Supreme Court refused to quash PMLA proceedings against JSW Steel, holding that questions on proceeds of crime must be decided by Appellate Tribunal first.
