DCIT, SITAPUR vs. THE DISTRICT COOPERATIVE BANK LAKHIMPUR KHERI LTD, LAKHIMPUR

ITA 513/LKW/2025Status: DisposedITAT Lucknow31 August 2026AY 2015-165 pages
AI SummaryRemanded

What did the Tribunal hold?

The Tribunal agreed with the Revenue that the CIT(A) should have verified whether the transactions were accounted for under the new PAN before deleting the addition. Therefore, the matter was restored to the CIT(A) for necessary verification.

What were the facts?

The Assessing Officer (AO) made an addition of Rs. 17,59,82,190/- on account of alleged escaped income after the assessee, a cooperative bank, failed to file a return for AY 2015-16 and did not respond to notices. The assessee claimed the transactions were recorded under a new PAN after the old one, allotted with incorrect company status, was surrendered.

What were the issues?

Whether the CIT(A) erred in deleting the addition without proper verification of the transactions under the new PAN, and whether the reassessment proceedings were valid given the PAN issue.

Which sections of the Income-tax Act were involved?

Section 147,Section 144,Section 148,Section 142(1),Section 148A(b),Section 148A(d)

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, LUCKNOW ‘B’ BENCH, LUCKNOW

Before: SH. SUDHANSHU SRIVASTAVA & SH. NIKHIL CHOUDHARY

Hearing: 13.08.2026Pronounced: 31.08.2026

PER NIKHIL CHOUDHARY, A.M.: This is an appeal filed by the Revenue against the order of the ld. CIT(A) dated 27.06.2025, wherein the ld. CIT(A) has allowed the appeal of the assessee against the order of the ld. Assessing Officer passed under section 147 r.w.s. 144 for the assessment year 2015-16 dated 29.03.2023. The grounds of appeal are as under:- “1. Ld. CIT(A) has erred in law and on facts of the case by deleting the addition without verification and adjudication of the facts

2.

Ld. CIT(A) has erred in law and on facts without examining the transaction even after having co-terminus power with the AO by simply saying that matter is subject to verification and adjudication which makes the order perverse.

3.

Ld. CIT(A)

The order continues below.

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