PRATIMA SINGH,AGRA vs. ITO, WARD 2(1)(2), AGRA/, AGRA

ITA 360/AGR/2026Status: DisposedITAT Agra24 August 2026AY 2020-219 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that the notice issued under Section 148A(b) of the Income Tax Act was bad in law as it was issued for mere verification and not to show cause why a notice under Section 148 should not be issued. Consequently, the reassessment proceedings and the assessment order were quashed.

What were the facts?

The Assessing Officer (AO) reopened the assessee's case for AY 2020-21 based on information regarding a property purchased below circle rate and unsubstantiated agricultural income. The AO disallowed the agricultural income and added the difference in property value to the total income.

What were the issues?

Whether the notice issued under Section 148A(b) of the Income Tax Act, 1961, was validly issued, and if not, whether it vitiates the subsequent reassessment proceedings.

Which sections of the Income-tax Act were involved?

Section 148A,Section 148,Section 56(2)(x),Section 147,Section 144B

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, AGRA (SMC

Before: SUNIL KUMAR SINGHBRAJESH KUMAR SINGH

For Appellant: Shri Rajesh Malhotra, CA
For Respondent: Shri Anil Kumar, Sr (DR)
Hearing: 06.07.2026Pronounced: 24.08.2026

PER:BRAJESH KUMAR SINGH, ACCOUNTANT MEMBER

This appeal is directed against the impugned order dated 26.02.2026 passed in appeal No NFAC/2019-20/10513426 by the ld. Commissioner of Income Tax (Appeals)/ NFAC(Delhi) (hereinafter referred to as the “CIT(A) u/s. 250 of the Income Tax Act, 1961 (hereinafter referred to as the “Act”) for the A.Y. 2020-21, wherein ld CIT(A) has dismissed assessee’s appeal.

2.

Brief facts of the case: In this case the AO had information that the assessee had purchased an immovable property for sale consideration of Rs. 6,11,600/-, while the circle rate for the property was Rs. 8,31,000/-. The AO noted that the difference amounting to Rs. 2,19,400/- (Rs. 8,31,000 – Rs. 6,11,600)

The order continues below.

Read the full judgment

A free account opens 10 full judgments a month. Re-reading one you have already opened does not count again.

Create a free accountSign in

See plans and prices

The summary, the parties, the sections and the citations above are open to everyone and always will be. Only the text of the order and the PDF are metered.

More judgments on Section 148A

All 3,543 judgments and leading authorities on Section 148A →

Recent GST High Court judgments

Search GST case law →