#Remand for Fresh Assessment

The ITAT Guwahati ruled that cash deposits in an individual’s account, made solely as a fiduciary agent for a cooperative society and fully accounted for through corresponding business debits, cannot be treated as unexplained income under Section 69A. This sets a critical precedent for cooperative societies and their administrative agents, affirming that functional role and fund tracing override mere possession in tax assessments.

ITAT Mumbai rules that the issuance of a Section 143(2) notice by the Jurisdictional Assessing Officer does not invalidate a faceless assessment under Section 144B. The Tribunal remanded the case for fresh adjudication on merits, reinforcing that procedural compliance under faceless assessment regimes does not override jurisdictional authority. This ruling clarifies the interplay between jurisdictional notices and faceless assessment procedures, impacting tax assessees and revenue authorities alike.