M/S. DNA MEDIA PVT. LTD.,LUCKNOW vs. INCOME TAX OFFICER 2(1), LUCKNOW

ITA 216/LKW/2025Status: DisposedITAT Lucknow13 July 2026AY 2017-1810 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that the reassessment proceedings were invalid because the approval for issuing the notice under section 148 was obtained from the Principal Commissioner of Income Tax (PCIT) instead of the Principal Chief Commissioner of Income Tax (PCCIT), as required for assessments beyond three years. Consequently, the reassessment order was quashed.

What were the facts?

The assessee company had made significant cash deposits during the demonetization period and failed to provide satisfactory explanations or supporting documents for these deposits. The Assessing Officer treated these deposits as unexplained income and made additions to the assessee's income.

What were the issues?

The primary issue was the validity of the reassessment proceedings due to improper approval for the notice under Section 148, and whether the cash deposits were correctly treated as unexplained income.

Which sections of the Income-tax Act were involved?

Section 147,Section 148,Section 148A,Section 151,Section 69A,Section 115BBE,Section 143(2),Section 145(3),Section 271AAC(1)

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, LUCKNOW ‘A’ BENCH, LUCKNOW

Hearing: 28.04.2026Pronounced: 13.07.2026

PER NIKHIL CHOUDHARY, A.M.: This is an appeal filed by the assessee against the orders of the ld. CIT(A), NFAC under section 250 of the Income Tax Act, 1961 on 25.02.2025, wherein the ld. CIT(A) has dismissed the appeals of the assessee against the orders passed by the Assessing Officer under section 147 r.w.s. 144 r.w.s. 144B of the Income Tax Act for the A.Y. 2017-18 on 19.05.2023. The grounds of appeal are as under:- “1 That the reassessment proceeding is unlawful and without juri iction as the approval has been given by PCIT u/s 151(i) instead of PCCIT u/s 151(ii) of the Income Tax Act, 1961 as required u/s 151 of the Income Tax Act, 1961 and also held by the Apex Court in the case of Rajeev Bansal.

The order continues below.

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