JASMEEN BINDRA,BAREILLY vs. INCOME TAX OFFICER 1(1), WARD-1(1), BAREILLY

ITA 420/LKW/2025Status: DisposedITAT Lucknow11 June 2026AY 2015-169 pages
AI SummaryDismissed

What did the Tribunal hold?

The Tribunal held that rectification proceedings under Section 154 are for mistakes apparent from the record and not for debatable issues. The CIT(A) had already implicitly decided the issue of reassessment validity, and a review of that decision was not permissible under Section 154.

What were the facts?

The assessee's assessment was set aside by the CIT(A) to the AO for fresh assessment. The assessee then filed a rectification application under Section 154, which was rejected by the CIT(A). The assessee appealed against the rejection of the rectification application.

What were the issues?

Whether the CIT(A) erred in rejecting the rectification application for not adjudicating the validity of reassessment proceedings, and whether the reassessment proceedings were validly initiated.

Which sections of the Income-tax Act were involved?

Section 147,Section 148,Section 154,Section 251(1)(a)

AI-generated summary — verify with the full judgment below

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

Before: SHRI KUL BHARAT, VICE- & SHRI ANADEE NATH MISSHRA

For Appellant: Shri Rakesh Garg, Advocate

PER ANADEE NATH MISSHRA:A.M.

(A) This appeal has been filed by the assessee against the impugned appellate order of learned CIT(A) / NFAC, Delhi, dated 23.04.2025, for AY 2015-16. The assessee has raised the following grounds of appeal:

“1. The Learned CIT(A) has erred in law and facts in setting aside the assessment of the assessee back to the file of the Assessing officer without adjudicating the legal issue challenging the assumption of juri iction of the Assessing officer to initiate reassessment proceedings in the hands of the assessee.

2.

The Learned CIT(A) has erred in law and facts in disposing off the Rectification application of the assessee requesting to adjudicate the legal

The order continues below.

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