Faceless reassessment transfers permit jurisdictional completion, while bank and ELSS evidence defeats disputed tax additions.
Faceless reassessment under Section 147 may be transferred on a case-by-case basis from NFAC to the Jurisdictional Assessing Officer, who may validly complete it; the draft-order procedure under Section 144B does not apply where that officer completes the reassessment. A deduction for political contributions may be disallowed where investigation material, banking trail and the recipient political party's identified modus operandi support disallowance. Detailed bank narration of receipts and repayments can explain disputed credits and preclude treatment as unexplained money. Ledger evidence of ELSS mutual-fund investment supports a claimed Section 80C deduction.
Issues: (i) Whether the Jurisdictional Assessing Officer could resume and complete reassessment after faceless proceedings had been conducted by NFAC; (ii) Whether non-issuance of a draft assessment order invalidated the reassessment; (iii) Whether the disallowance of deduction for political contribution under Section 80GGC was sustainable; (iv) Whether the addition as unexplained money under Section 69A was sustainable; (v) Whether the disallowance of deduction under Section 80C was sustainable.
Issue (i): Whether the Jurisdictional Assessing Officer could resume and complete reassessment after faceless proceedings had been conducted by NFAC.
Analysis: Section 144B provides for faceless assessment, including reassessment under Section 147, and Notification No. 18/2022 prescribes faceless reassessment through automated allocation. Although notices and the assessee's detailed response had been processed through NFAC, the Ministry of Finance communication permitted transfer of assessments from NFAC to the Jurisdictional Assessing Officer on a case-to-case basis. The final order by the Jurisdictional Assessing Officer was therefore treated as consistent with the applicable reassessment procedure.
Conclusion: The Jurisdictional Assessing Officer had jurisdiction to pass the reassessment order; the assessment was valid. This issue was decided against the assessee.
Issue (ii): Whether non-issuance of a draft assessment order invalidated the reassessment.
Analysis: Section 144C requires a draft assessment order for an eligible assessee, while the draft-order procedure under Section 144B applies to assessment proceedings conducted by NFAC. Since the reassessment was completed by the Jurisdictional Assessing Officer, the draft-assessment requirement under Section 144B was found inapplicable.
Conclusion: Non-issuance of a draft assessment order did not invalidate the reassessment. This issue was decided against the assessee.
Issue (iii): Whether the disallowance of deduction for political contribution under Section 80GGC was sustainable.
Analysis: The disallowance was supported by investigation material, the banking trail, and the identified modus operandi of the recipient political party. The reasoning adopted in comparable coordinate-bench decisions was followed, and no infirmity was found in the disallowance.
Conclusion: The disallowance of deduction under Section 80GGC was sustained. This issue was decided against the assessee.
Issue (iv): Whether the addition as unexplained money under Section 69A was sustainable.
Analysis: The bank statements placed on record contained detailed narration of receipts and repayments from various persons. This material sufficiently explained the impugned bank transactions despite the earlier finding that the explanations lacked adequate corroboration.
Conclusion: No addition under Section 69A was warranted. This issue was decided in favour of the assessee.
Issue (v): Whether the disallowance of deduction under Section 80C was sustainable.
Analysis: The record contained the ledger folio evidencing investment in an ELSS mutual fund. The available documentary evidence established the claimed deduction.
Conclusion: No disallowance under Section 80C was warranted. This issue was decided in favour of the assessee.
Final Conclusion: The reassessment and the Section 80GGC disallowance remained valid, while the additions relating to unexplained money and the Section 80C deduction were deleted.
Ratio Decidendi: A reassessment transferred from the faceless framework to the Jurisdictional Assessing Officer under the applicable procedure may validly be completed by that officer, and the draft-assessment requirement under Section 144B applies only to proceedings conducted by NFAC.