MUNNI DEVI,FIROZABAD vs. ITO, WARD-2(2)(2), FIROZABAD
Facts
The assessee, a non-filer, deposited Rs. 34,00,000/- in her bank account. The Assessing Officer (AO) reopened the assessment and added Rs. 30,00,000/- as unexplained cash credit, as the sale consideration of agricultural land was found to be Rs. 4,00,000/-. The CIT(A) upheld the addition.
Held
The Tribunal held that the sanction for reopening the assessment under Section 151 of the Act was granted mechanically without application of mind. Therefore, the reassessment proceedings were invalid and quashed.
Key Issues
Whether the reopening of assessment under Section 147/148 was valid due to mechanical approval under Section 151. Whether the addition of Rs. 30,00,000/- as unexplained cash credit was justified.
Sections Cited
Section 69A, Section 147, Section 148, Section 151
AI-generated summary — verify with the full judgment below
Income Tax Appellate Tribunal, AGRA(SMC
Before: AND BRAJESH KUMAR SINGH
PER: SUNIL KUMAR SINGH, J.M.
This appeal is directed against the impugned order dated 10.03.2026 passed in appeal No CIT(Appeal) 2, Agra/10341/2018-19by the ld. Commissioner of Income Tax(Appeal)/ADDL/JCIT(A)-1, Jaipur [(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. 2011-12,wherein ld CIT(A) has dismissed assessee’s appeal, confirming the addition of Rs. 30,00,000/- as unexplained cash deposit u/s 69A, made vide, assessment order dated 19.12.2018 passed u/s143(3)/147 of the Act.
The brief facts of the case are that the assessee is a non-filer. It was noticed by the department that the assessee deposited cash of Rs. 34,00,000/- in her bank account. The case w
The order continues below.
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