SHRI JATINDER KUMAR,MOGA vs. INCOME TAX OFFICER WARD-3, MOGA

ITA 49/ASR/2024Status: DisposedITAT Amritsar04 June 2026AY 2013-135 pages
AI SummaryRemanded

What did the Tribunal hold?

The Tribunal remanded the matter back to the CIT(A) for adjudication on merits, directing the assessee to file all necessary submissions and cooperate in the proceedings. The assessee was granted a reasonable opportunity of being heard.

What were the facts?

The assessee's appeal against an addition of Rs. 80.21 lakhs as unexplained investment was dismissed by the CIT(A) due to non-compliance. The AO initiated proceedings under Section 147 based on information regarding the assessee's investment in immovable properties.

What were the issues?

Whether the addition of unexplained investment under Section 69 was justified and whether the reassessment proceedings initiated under Section 147 were valid, including the approval under Section 151.

Which sections of the Income-tax Act were involved?

Section 69,Section 143(3),Section 147,Section 148,Section 151,Section 250

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, AMRITSAR BENCH, AMRITSAR.

Before: DR. DIPAK P. RIPOTE & SH. UDAYAN DAS GUPTA

Hearing: 18.03.2026

Per: Udayan Dasgupta, JM:

This appeal is filed by the assessee against the order of ld. CIT(A), NFAC, Delhi, passed u/s 250 of the IT Act, 1961, dated 18.12.2023, which has emanated from the order of the AO, Ward-3, Moga, passed u/s 143(3) r.w.s. 147 of the Act, dated 25.12.2019. 2. The grounds of appeal taken in Form 36 are as follows:

“1. That the worthy Commissioner of Income Tax (Appeals), National Faceless Appeal Centre (NFAC), Delhi has erred in confirming the action of the Learned Assessing Officer in making an addition of Rs.80,21,250/- as unexplained investment under section 69 of the IT Act, 1961 without any basis. Assessment Year: 2012-13 2

2.

That the worthy Commissioner of Inc

The order continues below.

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