GAUTAM KUMAR SINGH,ETAWAH vs. ITO,WARD 2(2)(5), ETAWAH, ETAWAH

ITA 256/AGR/2026Status: DisposedITAT Agra30 September 2026AY 2020-2116 pages
AI SummaryAllowed

What were the facts?

The assessee purchased an immovable property for Rs. 1,62,000, while its stamp duty value was Rs. 20,08,000. The Assessing Officer reopened the assessment and added both the purchase consideration and the difference between the stamp duty value and the consideration as unexplained investment. The CIT(A) upheld these additions.

What did the Tribunal hold?

The Tribunal held that the approval granted by the PCIT under Section 151 for issuing the notice under Section 148 was mechanical and without application of mind, rendering the reassessment proceedings invalid. Consequently, the reassessment order was quashed.

What were the issues?

Whether the reassessment proceedings initiated were valid given the alleged mechanical approval under Section 151, and whether the additions made under Sections 69 and 56(2)(x) were justified.

Which sections of the Income-tax Act were involved?

Section 147,Section 148,Section 151,Section 69,Section 56(2)(x)

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, AGRA(SMC

Before: SUNIL KUMAR SINGH & BRAJESH KUMAR SINGH

For Appellant: Shri Rajesh Malhotra, CA
For Respondent: Shri Anil Kumar,Sr (DR)
Hearing: 08.07.2026Pronounced: 30.09.2026

PER: SUNIL KUMAR SINGH, J.M.

This appeal is directed against the impugned order dated 26.12.2025 passed in appeal No NFAC/2019-20/10481234by the ld. Commissioner of Income Tax(Appeal)/ 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, confirming the impugned additions made by ld assessing officer.

2.

At the very outset, according to registry’s report, the assessee filed this second appeal on 25.03.2026 against the impugned order dated 26.12.2025 by a delay of about 24 days. The reasons mentioned in assessee’s application for condonation o

The order continues below.

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