ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-(1), BILASPUR vs. VIVEK AGRAWAL, BILASPUR

ITA 627/RPR/2025Status: HeardITAT Raipur05 August 2026AY 2017-1817 pages
AI SummaryDismissed

What did the Tribunal hold?

The Tribunal held that the reassessment proceedings were vitiated because the approval for reopening the assessment beyond three years was granted by the PCIT, not the Principal Chief Commissioner as required by Section 151(ii). Consequently, the reassessment order was quashed.

What were the facts?

The assessee deposited Rs. 95,50,000/- in cash during the demonetization period, which the Assessing Officer added as unexplained income. The CIT(A) deleted this addition. The Revenue appealed this deletion.

What were the issues?

Whether the reassessment proceedings are valid when the approval for reopening beyond three years was obtained from an incorrect authority as per Section 151(ii). Whether the addition made under Section 69A for unexplained cash deposits is justified.

Which sections of the Income-tax Act were involved?

Section 147,Section 148,Section 151,Section 69A

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, RAIPUR BENCH, RAIPUR

Before: JUSTICE (RETD.) SHRI C. V. BHADANG & SHRI R. K. PANDA

For Appellant: Shri G.S. Agrawal, CA
For Respondent: Shri Piyush Tripathi, Sr.DR

PER R.K. PANDA, VP:

This appeal filed by the Revenue is directed against the order dated 09.08.2025 of the Ld. CIT(A) / NFAC, Delhi relating to assessment year 2017-18. The assessee has filed the CO against the appeal filed by the Revenue. For the 2 CO No.27/PUN/2025

sake of convenience, the appeal filed by the Revenue and the CO filed by the assessee were heard together and are being disposed of by this common order.

2.

There is a delay of 19 days in filing of the CO by the assessee before the Tribunal for which the assessee has file

The order continues below.

Read the full judgment

A free account opens 10 full judgments a month. Re-reading one you have already opened does not count again.

Create a free accountSign in

See plans and prices

The summary, the parties, the sections and the citations above are open to everyone and always will be. Only the text of the order and the PDF are metered.

More judgments on Section 147

All 49,210 judgments and leading authorities on Section 147 →

Recent GST High Court judgments

Search GST case law →