UTTAR PRADESH GRAMIN BANK,LUCKNOW vs. ASSESSMENT UNIT, , DELHI
What did the Tribunal hold?
The Tribunal held that the CIT(A) erred in dismissing the appeal as infructuous, as the Section 143(1) adjustments were subject to the regular assessment order. The Tribunal found that the CIT(A) failed to consider the assessee's submissions and the revised audit report regarding contingent liabilities.
What were the facts?
The Assessing Officer (AO) completed a scrutiny assessment under Section 143(3) at Rs. 3,25,03,61,790/-, which was identical to the income determined under Section 143(1)(a). The assessee appealed to the CIT(A), arguing that the Section 143(1) order merged into the Section 143(3) order and that their submissions regarding contingent liabilities were not considered.
What were the issues?
Whether the CIT(A) was correct in dismissing the appeal as infructuous when the Section 143(1) adjustments were incorporated into the Section 143(3) assessment order, and whether the assessee's submissions on contingent liabilities were properly considered.
Which sections of the Income-tax Act were involved?
AI-generated summary — verify with the full judgment below
Income Tax Appellate Tribunal, LUCKNOW BENCH “B”, LUCKNOW
Before: SHRI KUL BHARAT & SHRI ANADEE NATH MISSHRA
PER KUL BHARAT, VICE PRESIDENT.:
This appeal, by the assessee, is directed against the order of the Learned Commissioner of Income-tax (Appeals), National Faceless Appeal Centre (NFAC), Delhi dated 29.10.2025 pertaining to the assessment year 2022-23. The assessee has raised the following grounds of appeal: -
“1. The Ld. CIT(A) has erred in law and on facts in not appreciating that the regular assessment order had been passed by the ld. Assessing Officer on 23.03.2024 did not constitute a valid order, as the same had been based on the income determined under section 143(1), which itself suffered from various infirmities; the Id. CIT(A) has erred in la
The order continues below.
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