THE GEORA AGRICULTURE CO OPERATIVE SERVICE SOCIETY LIMITED,KANGRA, HIMACHAL PRADESH vs. ITO WARD, NURPUR, ITO WARD, NURPUR
What did the Tribunal hold?
The Tribunal held that the notice under section 148 was issued beyond the period of limitation prescribed by the first proviso to section 149. It also noted that the notice was issued on an incorrect PAN, and the assessee had provided the correct PAN with supporting details.
What were the facts?
The assessee is challenging additions made by the Assessing Officer (AO) and confirmed by the CIT(A) on account of cash deposits and investments in FDRs. The assessee also contends that the notice under section 148 was barred by limitation and issued on an incorrect PAN.
What were the issues?
Whether the notice issued under section 148 was barred by limitation and whether it was correctly issued on the assessee's PAN.
Which sections of the Income-tax Act were involved?
AI-generated summary — verify with the full judgment below
Cause title — parties, addresses and appearances
आदेश/Order PER LALIET KUMAR, J.M: This appeal by the assessee is directed against the order dated 18.03.2025 passed by the Ld. CIT(A), NFAC, Delhi, arising out of the assessment framed under section 147 read with section 144B of the Income Tax Act, 1961 for the assessment year 2015–16. 2. In the present appeal Assessee has raised the following grounds:
That the CIT(A) has erred in facts and in law in confirming the addition made by the AO at Rs. 19375600 /- on account of cash deposited in bank and Rs. 7500000/- on account of investment in FDRs during the year under consideration.
That the CIT(A), while confirming the addition made by the Assessing Officer, has grossly erred both in law and on facts in ignoring the fact that the notice issued under section 148 dated 01.04.2022 is barred by limitation, as per the 1st proviso to section 149 of the Income Tax Act, 1961. 3. That the CIT(A) has erred in law and on facts in upholding the addition made by the Assessing Officer, without appreciating that the notice under section 148 was erroneously and deliberately issued on PAN AABTT9927E, instead of the correct PAN AAEAT6478N. The CIT(A) further failed to consider that the assessee had duly submitted a reply dated 25.03.2022, categorically informing the department that all the cash deposits and Fixed Deposit Receipts (FDRs) pertain to the correct PAN AAEAT6478N, and not to the PAN on which the notice was issued.
That the CIT(A) erred in sustaining the addition of Rs.1,93,75,600 towards cash deposits, primarily on the basis that the balance sheet submitted was not duly audited under a statutory audit and lacked the signature of a chartered accountant. This conclusion overlooks the fact that an internal audit was duly conducted under The Cooperative Societies Act 1860, by an Inspector of the
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
Recent GST High Court judgments
Search GST case law →- M/S Gujarat Co-Operative Milk Marketing Federation Limited vs. Union Of INDIAGujarat · 14 Oct 2026
- Ramesh K Devadiga vs. Khernagar Nandadeep Co Operative Housing Society LTDBombay · 14 Oct 2026
- Ramesh K Devadiga And Ors vs. Khernagar Nandadeep Co-Operative Housing Society LTD And OrsBombay · 14 Oct 2026
- Permender Singh vs. Union Of INDIA And Ors.Calcutta · 14 Oct 2026
- M/S Abdhish Dhal Samanta, Bhubaneswar vs. Chief Commissioner, CT And GST, Odisha, CuttackOrissa · 14 Oct 2026
