M/S. SUMATHI BAI INDUSTRIAL FINANCE INDIA LTD.,CHENNAI vs. DCIT, CC-3(1), CHENNAI

ITA 3279/CHNY/2025Status: DisposedITAT Chennai26 May 2026AY 2020-219 pages
AI SummaryRemanded

What were the facts?

The assessee's appeals for AY 2017-18 and 2020-21 involved identical facts and issues concerning reassessment proceedings. A search action led to the AO forming an opinion of escaped income, issuing a notice under Section 148, and making an addition for accrued interest on loans.

What did the Tribunal hold?

The Tribunal held that the jurisdictional assessing officer lacked the authority to issue the Section 148 notice, as this power was vested with the Faceless Assessment Unit. Due to a recent Supreme Court order setting aside High Court decisions on similar jurisdictional issues, the matter was remanded.

What were the issues?

The primary issue was the validity of reassessment proceedings initiated by the jurisdictional assessing officer instead of the faceless assessment unit. Another key issue involved the addition of accrued interest on outstanding loans.

Which sections of the Income-tax Act were involved?

Section 148,Section 147,Section 151A,Section 132,Section 143(1),Section 139(1),Section 142(1),Section 36(1)(vii),Section 36(2),Section 43D

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, CHENNAI BENCHES, CHENNAI

Before: HON’BLE INTURI RAMA RAO & HON’BLE MANU KUMAR GIRI

PER INTURI RAMA RAO, ACCOUNTANT MEMBER:

These two appeals filed by the Assessee are directed against the separate orders of ld.Com

The order continues below.

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