AMARJIT SINGH GREWAL,LUDHIANA vs. ITO, JAGRAON

ITA 564/CHANDI/2026Status: DisposedITAT Chandigarh08 September 2026AY 2012-20133 pages
AI SummaryRemanded

What did the Tribunal hold?

The Tribunal found that the additional evidence submitted by the assessee, including appellate orders in the actual owner's case, was crucial. Therefore, the matter was set aside and restored to the Assessing Officer for a fresh assessment.

What were the facts?

The assessee's appeal pertains to AY 2012-13, arising from an assessment framed on a best judgment basis due to lack of representation. The assessee claims to have sold property as a GPA holder for the actual owner, whose capital gains were assessed separately.

What were the issues?

Whether the capital gains assessment made on a best judgment basis is sustainable when the assessee provides crucial additional evidence regarding the actual ownership and prior assessment of capital gains.

Which sections of the Income-tax Act were involved?

Section 147,Section 144

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, “A” BENCH, CHANDIGARH

Before: HON’BLE SHRI MANOJ KUMAR AGGARWAL, AM & HON’BLE SHRI RAJESH DAMODARLAL SHARMA, JM

RAJESH DAMODARLAL SHARMA (Judicial Member)

1.

Aforesaid appeal by the assessee for Assessment Year (AY) 2012-13 arises out of an order of learned Commissioner of Income Tax (Appeals), NAFC [CIT(A)] dated 20.01.2026 in the matter of an assessment framed by Ld. Assessing Officer [AO] on best judgment basis u/s 147 r.w.s. 144 of the Act on 24.12.2019. In the assessment order, Ld. AO assessed capital gain of Rs.193.09 Lacs for want

The order continues below.

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