SURESHBHAI PRAGJIBHAI PARMAR,RAJKOT vs. THE INCOME TAX OFFICER, WARD-1(2)(4), RAJKOT

ITA 864/RJT/2024Status: DisposedITAT Rajkot08 September 2026AY 2010-114 pages
AI SummaryRemanded

What did the Tribunal hold?

The Tribunal noted that the validity of the reassessment proceedings hinged on the proper service of the notice under section 148. As the assessment records were not available, the issue was restored to the Assessing Officer for verification of the notice's service.

What were the facts?

The assessee failed to file a return of income for AY 2010-11. The Assessing Officer reopened the assessment under section 147 based on substantial cash deposits in the assessee's bank account. The assessment was completed ex parte under section 144 as the assessee did not comply with notices.

What were the issues?

Whether the reassessment proceedings initiated under section 147 were valid due to the alleged non-service of the notice under section 148.

Which sections of the Income-tax Act were involved?

Section 147,Section 148,Section 144,Section 250,Section 133(6),Section 271(1)(c),Section 271(1)(b)

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, Rajkot Bench, Rajkot

Before: Dr. Arjun Lal Saini & Shri Sonjoy Sarma

For Appellant: Shri Rushit Sheth, Ld. AR
For Respondent: Shri Ganesh Iyer, Ld. Sr. DR
Hearing: 01/09/2026Pronounced: 08/09/2026

Per, Shri Sonjoy Sarma, JM: Captioned appeal filed by the assessee, pertaining to Assessment Year (AY) 2010-11, is directed against the order under section 250 of the Income-tax Act, 1961 [hereinafter referred to as ‘the Act’] passed by the National Faceless Appeal Centre [hereinafter referred to as ‘NFAC’], dated 10.10.2024, which in turn arises out of an order passed by assessing officer u/s. 144 of the Act, dated 27.12.2017. 02. Brief facts of the

The order continues below.

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