MD JIAUDDIN AHMED,GUWAHATI vs. ITO, GUWAHATI

ITA 150/GTY/2019Status: DisposedITAT Guwahati16 September 2026AY 1991-9214 pages
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What did the Tribunal hold?

The Tribunal held that the assessment orders were passed within the prescribed limitation period, as the limitation was to be counted from the date of the Miscellaneous Application order. Regarding the additions, the Tribunal directed the assessee to provide a status report on the CBI proceedings and the Assessing Officer to re-examine the case.

What were the facts?

The assessee's case was reopened due to involvement in a CBI charge sheet for swindling public money. After multiple remands and appeals, the Assessing Officer passed fresh assessment orders. The assessee appealed against these orders, primarily on grounds of limitation and lack of evidence for additions.

What were the issues?

Whether the assessment orders were passed beyond the period of limitation prescribed under Section 153 of the Income Tax Act, and whether the additions made were based on suspicion and surmises without cogent evidence.

Which sections of the Income-tax Act were involved?

Section 144,Section 147,Section 143(3),Section 250,Section 254,Section 153

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, GUWAHATI ‘DB’ BENCH

Before: SHRI LAXMI PRASAD SAHU & SHRI YOGESH KUMAR U.S.

For Appellant: Shri S.P. Bhati, FCA
For Respondent: Shri PS Thuingaleng, CIT, DR
Hearing: 09.09.2026Pronounced: 16.09.2026

PER YOGESH KUMAR U.S., JUDICIAL MEMBER:

The captioned Appeals are filed by the Assessee against the orders of the Commissioner of Income Tax (Appeals) (‘Ld. CIT(A)’ for short) dated 28.03.2019 passed u/s 250 of the Income Tax Act, 1961 (“the Act”, for short) pertaining to the Assessment Years 1991-92, 1992-93 & 1993-94. 2. Since the above Appeals are filed by the single Assessee, having identical issues to be decided, the captioned Appeals are heard together and decided in this common order.

ITA Nos.150, 151 & 152/GTY/2019 Md Jiauddin Ahmed; A.Ys.: 1991-92, 1992-93 & 1993-94

3.

Brief facts of the case are that

The order continues below.

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