ANIL AGRAWAL, RAIPUR,RAIPUR vs. INCOME TAX OFFICER, WARD-1(2), RAIPUR, RAIPUR

ITA 73/RPR/2025Status: DisposedITAT Raipur05 August 2026AY 2017-1819 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that the notice under Section 148 was issued beyond the surviving time limit and that the approval for reassessment was not obtained from the appropriate authority as required by Section 151. Consequently, the reassessment proceedings were quashed.

What were the facts?

The assessee was found to have received accommodation entries for fictitious purchases amounting to Rs. 5,91,23,537. The Assessing Officer reopened the assessment and made additions based on this information. The assessee challenged the validity of the reassessment proceedings.

What were the issues?

Whether the reassessment proceedings are valid when the notice under Section 148 is time-barred and the approval under Section 151 is not obtained from the prescribed authority.

Which sections of the Income-tax Act were involved?

Section 147,Section 148,Section 151,Section 69C,Section 37

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:

The above 2 appeals filed by the assessee are directed against the separate orders dated 04.01.2025 of the Ld. CIT(A) / NFAC, Delhi relating to assessment years 2016-17 and 2017-18 respectively. For the sake of convenience, both these appeals were heard together and are being disposed of by this common order.

2.

Facts of the case, in brief, are that the assessee is an individual and engaged in the business of trading of grains. He filed his return of income on 27.09.2016 declaring total income of Rs.14,69,400/-. The Assessing Officer completed the assessment u/s 143(3) of the Income Tax Act, 1961 (hereinafter referred to as ‘the Act’) on 30.10.2018. Subsequently, info

The order continues below.

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