DEPUTY COMMISSIONER OF INCOME TAX, RAIPUR vs. ANAND KUMAR AGARWAL, RAIPUR

ITA 707/RPR/2025Status: DisposedITAT Raipur05 August 2026AY 2019-2011 pages
AI SummaryDismissed

What did the Tribunal hold?

The Tribunal held that the reassessment notice issued by the Assessing Officer was invalid as it provided a shorter period (90 days) than prescribed by law (3 months from the end of the month of issue). This was considered a jurisdictional defect.

What were the facts?

The Assessing Officer made an addition of Rs. 1,56,00,000/- as unexplained investment based on seized documents indicating cash payment for land. The CIT(A) deleted this addition, but dismissed the assessee's legal ground challenging the reassessment proceedings.

What were the issues?

Whether the reassessment proceedings were validly initiated given the shorter notice period provided to the assessee, and whether the addition on account of unexplained investment was justified.

Which sections of the Income-tax Act were involved?

Section 148,Section 143(3),Section 147,Section 69,Section 115BBE,Section 151

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 Ravi 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 10.09.2025 of the Ld. CIT(A) / NFAC, Delhi relating to assessment year 2019-20. The assessee has filed the CO against the appeal filed by the Revenue. For the 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 CO No.1/RPR/2026

2.

Facts of the case, in brief, are that the assessee is an individual and filed his return of income on 21.10.2019 declaring total income of Rs.28,85,660/-. Th

The order continues below.

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