2026 (5) TMI 849

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....jeev Bansal [SC] and needs to be quashed. 2. The Assessment Unit Tax Department (AUTD) as well as CIT(A) faceless erred while disallowing the legitimate expenses made as improving cost on property, ignoring the evidence already filed on 07/04/2022. 3. The AUTD as well as CIT(A) faceless erred while disallowing expenses of Rs. 7,78,684/- as against actual the claim of Rs. 7,55,624/-. 4. The CIT(Appeals) Income Tax Department confirmed the disallowance of cost of Improvement of (Rs. 7,55,624/- OR Rs. 7,78,684/- as erroneous amount), by ignoring the facts. 5. The AUTD erred while levying the interest u/s. 234A, 234B, &; 234C. 6. The AUTD erred while initiating the penalty u/s. 271(1)(c), for expense....

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....Amendment of Certain Provisions) Act, 2020 ("TOLA"). Therefore, according to the assessee, once such concession had been recorded before the Hon'ble Apex Court, the Ld. AO ought to have dropped the reassessment proceedings and could not have proceeded to pass the reassessment order. 3.2. The Ld. DR, on the other hand, fairly did not dispute the fact that the Hon'ble Supreme Court in the case of Rajeev Bansal (supra) had recorded the submissions of the Ld. Additional Solicitor General of India to the effect that, for A.Y. 2015-16, all notices issued u/s 148 on or after 01/04/2021 would have to be dropped as they would not fall for completion within the limitation period prescribed under the Taxation and Other Laws (Relaxation and Amendmen....