DALEL SINGH,SONIPAT vs. INCOME TAX OFFICER WARD-1, SONIPAT
In favour of the assessee: the assessee's appeal was allowed. From the AI summary of this appeal.
What did the Tribunal hold?
The Tribunal held that the Assessing Officer had not recorded that the cash deposits represented income that had escaped assessment. Therefore, the Tribunal quashed the impugned reopening.
What were the facts?
The assessee filed an appeal against an order that arose from proceedings under Section 143(3) read with Section 147 of the Income Tax Act, 1961. The Assessing Officer initiated Section 148/147 proceedings for verification of the source of cash deposits in a bank account.
What were the issues?
The primary issue was the validity of the reopening of assessment under Section 147 of the Income Tax Act.
Which sections of the Income-tax Act were involved?
AI-generated summary — verify with the full judgment below
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- Le Passage to India Tours & Travels (P.) Ltd. v. Addl. CIT3 citing58 Taxmann.com 144 · 2015 · HC
Income Tax Appellate Tribunal, DELHI BENCH ‘SMC’, NEW DELHI
Before: Sh. Satbeer Singh Godara
Asstt. Year: 2012-13 Dalel Singh, Vs Income Tax Officer, 209, Rewali, Sonepat, Ward-1, Haryana-131039 Sonepat, Haryana-131001 (APPELLANT) (RESPONDENT) PAN No. BOVPS5820L Assessee by: Sh. Samyak Jain, CA & Sh. Subodh, Adv. Revenue by : Sh. Manoj Kumar, Sr. DR Date of Hearing: 23.07.2025 Date of Pronouncement: 23.07.2025 ORDER This assessee’s appeal for Assessment Year 2012-13 arises against the Addl./JCIT(A)-2, Chennai’s DIN & order No. ITBA/APL/S/250/2024-25/1075011854(1) dated 25.03.2025, in proceedings u/s 143(3) r.w.s. 147 of the Income Tax Act, 1961 (in short “the Act”).
Heard both the parties at length. Case file perused.
It emerges during the course of hearing that there arises the first and foremost legal issue of validity of the impugned reopening itself as the learned Assessing Officer makes it clear in his assessment order dated 15.12.2019 in para 1 that he had set into motion section 148/147 proceedings “for verification of the source of cash amount deposited in bank account and for verification of other bank entries”.
Dalel Singh 4. The above being the clinching factual position, it is clear that the learned Assessing Officer had nowhere recorded that the assessee’s above cash deposits infact represented his income liable to be assessed having escaped assessment; and, therefore, in light of Le Passage to India Tours & Travels (P.) Ltd. Vs. Addl. CIT (2015) 58 taxmann.com 144 (Delhi), this tribunal hereby quash the impugned reopening in very terms. Ordered accordingly.
All other pleadings on merits stand rendered academic.
More judgments on Section 147
- ACIT Central Bilaspur, Bilaspur vs Arun Kumar Agrawal, SaktiITSSA 26/RPR/2025[2018-19]Status: Disposed21 Oct 2026AY 2018-19
- Vinod Agrawal, Kawardha vs Assisstant Commissioner of Income Tax…ITA 666/RPR/2026[2019-20]Status: Heard21 Oct 2026AY 2019-20
- Sar Business Tradelink Private Limited… vs Income Tax Officer, Ward - 1(2), RaipurITA 599/RPR/2026[2014-15]Status: Heard21 Oct 2026AY 2014-15
- Tarunaben Maganlal Bhut, Navagam vs ITO Ward 2(2)(1), RajkotITA 673/RJT/2026[2024-25]Status: Disposed21 Oct 2026AY 2024-25
- Neo Incorporation, Rajkot vs DCIT Circle- 1(2), RajkotITA 471/RJT/2026[2012-2013]Status: Disposed21 Oct 2026AY 2012-2013
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