M/S. MAHARANA PRATAP POLYTECHNIC SOCIETY ,UTTAR PRADESH vs. DCIT, LUCKNOW

ITA 1/LKW/2026Status: DisposedITAT Lucknow09 June 2026AY 2016-176 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that the reassessment proceedings were invalid as they constituted a review of the earlier assessment. Additionally, the Tribunal found that the assessee was not given a reasonable opportunity to present evidence due to the hasty manner in which the assessment order was passed.

What were the facts?

The assessee's original assessment was accepted. Later, reassessment proceedings were initiated under Section 147, leading to an addition of Rs. 2,82,95,535/- on account of cash deposits treated as unexplained. The CIT(A) confirmed this addition.

What were the issues?

Whether reassessment proceedings under Section 147 were validly initiated when the issue was already examined in the original assessment. Whether the assessee was provided a reasonable opportunity to be heard during the reassessment proceedings.

Which sections of the Income-tax Act were involved?

Section 147,Section 144,Section 69A,Section 143(3)

AI-generated summary — verify with the full judgment below

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

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

For Appellant: Shri S. Krishnan, CA

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 12.02.2025, for the AY 2016-17. The assessee has raised the following grounds of appeal:

“1. On the facts and in the circumstances of the case and in law, National Faceless Appeal Centre ('NFAC') erred in confirming validity of assessment framed u/s.148 of the Act.

2.

On the facts and in the circumstances of the case and in law, National Faceless Appeal Centre ('NFAC') erred in not condoning delay of 127 days in the filing of the appeal before it. Assessment Year: 2016-17 2

3.

On the facts and in the circu

The order continues below.

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