DEEPAK GOYAL,LUDHIANA vs. INCOME TAX OFFICER, LUDHIANA

ITA 485/CHANDI/2026Status: DisposedITAT Chandigarh19 August 2026AY 2012-133 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that no prejudice would be caused to the assessee if the matter is reheard by the AO. It restored the legal ground regarding the validity of proceedings under section 147/148 back to the AO for de novo assessment.

What were the facts?

The assessee's original assessment was completed under section 143(3) r.w.s. 147. Subsequently, the AO reopened the assessment under section 147, alleging no compliance and no return filed, leading to an addition of Rs. 29,00,000/- for cash deposits. The CIT(A) set aside the assessment order to the AO.

What were the issues?

The primary issues were the validity of reopening the assessment under section 147 when a previous assessment on the same issue was already completed, and the merits of the addition made by the AO.

Which sections of the Income-tax Act were involved?

Section 147,Section 143(3),Section 148

AI-generated summary — verify with the full judgment below

Cause title — parties, addresses and appearances
आयकर अपीलीय अिधकरण,च"ीगढ़ "ायपीठ “ए” , च"ीगढ़ IN THE INCOME TAX APPELLATE TRIBUNAL, CHANDIGARH BENCH “A”, CHANDIGARH HEARING THROUGH: HYBRID MODE "ी लिलत कुमार, "ाियक सद" एवं "ी िवजय वमा" , लेखा सद" BEFORE: SHRI. LALIET KUMAR, JM & SHRI. VIJAY VARMA, AM आयकर अपील सं./ ITA No. 485/Chd/ 2026 िनधा"रण वष" / Assessment Year : 2012-13 Deepak Goyal बनाम The ITO 57, Victoria Colony, Guru Amar Das Ward 7(1), Ludhiana Nagar, Rajguru Nagar, Ludhiana Punjab-141012 "ायी लेखा सं./PAN NO: ABHPG9676Q अपीलाथ"/Appellant ""थ"/Respondent िनधा"रती की ओर से/Assessee by : Shri Sanjeev Gupta, C.A (Virtual) राज" की ओर से/ Revenue by : Shri Vivek Vardhan, Addl. CIT, Sr. DR सुनवाई की तारीख/Date of Hearing : 17/08/2026 उदघोषणा की तारीख/Date of Pronouncement : 19/08/2026

आदेश/Order PER VIJAY VARMA, A.M: This is an appeal filed by the Appellant against the order of the Ld. CIT(A)/NFAC, Delhi dt. 06/01/2026 for the Assessment Year 2012-13 in appeal No. NFAC/2011-12/10116013. 2. In the present appeal, Appellant has raised the following grounds:

1.

That the Honorable CIT (A) has erred in not cancelling the assessment made by AO under section 147 of the Income Tax Act vide order dated 22.12.2019 by considering that

The order continues below.

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