CHARAN SINGH,ALIGARH vs. INCOME TAX OFFICER 1(4), ALIGARH, ALIGARH
Facts
The assessee, a non-filer for AY 2012-13, purchased agricultural land. The Assessing Officer (AO) reopened the case and added Rs. 28,30,000/- as unexplained investment. The CIT(A) dismissed the assessee's appeal, confirming the addition.
Held
The Tribunal held that the approval for reopening the assessment under Section 151 of the Act was granted mechanically without application of mind, rendering the reassessment proceedings invalid. Consequently, the reassessment order was quashed.
Key Issues
Whether the approval for reopening the assessment under Section 151 was validly granted, and if not, whether the reassessment proceedings are vitiated.
Sections Cited
Section 147, Section 148, Section 151, Section 250
AI-generated summary — verify with the full judgment below
Income Tax Appellate Tribunal, AGRA (DB
Before: AND BRAJESH KUMAR SINGH
PER: SUNIL KUMAR SINGH, J.M.
This appeal is directed against the impugned order dated 04.02.2026 passed in appeal NoCIT(A) Aligarh/10634/2017-18by the ld. Commissioner of Income Tax(Appeal)/ ADDL/JCIT(A)-1Nashik[(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. 2012-13,wherein ld CIT(A) has dismissed assessee’s appeal, confirming the addition of Rs. 28,30,000/- as unexplained investment made vide, assessment order dated 26.12.2016 passed u/s143(3)/147 of the Act.
The brief facts of the case are that assessee is a non-filer for A.Y. 2012-13. Revenue had an information that assessee purchased agricultural land situated at Vill-Jaupura, Dist-Agra on 28.
The order continues below.
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