TULSI INFRAHEIGHTS PRIVATE LIMITED,AGRA vs. DCIT, CIRCLE-2(1)(1), AGRA
Facts
The assessee's case was reopened under Section 147 based on information regarding accommodation entries. The Assessing Officer added the amount of these entries and a commission as unexplained income. The CIT(A) upheld these additions.
Held
The Tribunal held that the approval for reopening the assessment under Section 151 was granted mechanically without application of mind, rendering the reassessment proceedings invalid. Consequently, the reassessment order was quashed.
Key Issues
The primary issue was the validity of the reassessment proceedings due to a mechanical approval under Section 151. The secondary issue concerned the validity of additions made under Section 68 based on alleged accommodation entries.
Sections Cited
Section 147, Section 148, Section 151, Section 68
AI-generated summary — verify with the full judgment below
Income Tax Appellate Tribunal, AGRA(DB
PER: SUNIL KUMAR SINGH, J.M.
This appeal is directed against the impugned order dated 04.02.2026 passed in appeal No CIT(A)-IV/KNP/10502/2019-20 by the ld. Commissioner of Income Tax(Appeals), Kanpur-4 [(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. 1,71,68,750/- as unexplained income, made vide, assessment order dated 29.12.2019 passed u/s143(3)/147 of the Act.
The brief facts of the case are that the assessee filed his return of income for A.Y. 2012-13 on 28.09.2012, declaring total income at nil. In pursuance of a s
The order continues below.
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