ANITA MITTAL,JAIPUR vs. ITO, WARD-1(3), JAIPUR, JAIPUR

ITA 98/JPR/2026Status: DisposedITAT Jaipur06 October 2026AY 2016-178 pages
AI SummaryRemanded

What did the Tribunal hold?

The Tribunal noted that the assessee had requested a copy of the sale deed and Power of Attorney dated 30.11.2015. The judgment states that the assessee submitted her bank account wherein no such transaction of sale of immovable property was reflected. The Tribunal's decision on the validity of the reassessment proceedings and the alleged property sale transaction is not explicitly recorded in the provided excerpt. The excerpt ends with the assessee's request for documentation and her submission of bank account details. Therefore, the Tribunal's finding on the specific issue of reassessment validity and the treatment of the alleged income is not ascertainable from this portion of the judgment. No operative directions or specific relief granted are mentioned.

What were the facts?

The assessee, Anita Mittal, an individual, filed her return of income for Assessment Year 2016-17 on March 10, 2017, declaring a total income of Rs. 2,69,760. The Revenue, based on information that the assessee sold an immovable property for Rs. 1.11 crores along with three other individuals, with her share being Rs. 27,75,000, initiated reassessment proceedings. The assessment was reopened by issuing notices under Section 148 of the Income Tax Act, 1961, on March 31, 2021, and April 9, 2021. The assessee, in response, provided her bank account details, stating no such property sale transaction was reflected. She also requested a copy of the sale deed and Power of Attorney dated November 30, 2015. The appeal is against the appellate order dated December 30, 2025, passed by the Commissioner of Income Tax (Appeal), NFAC, Delhi, arising from a reassessment order under Section 147 read with Section 144B of the Act.

What were the issues?

1. Whether the reassessment proceedings initiated under Section 147 read with Section 148 of the Income Tax Act, 1961, are valid, considering the information available to the Revenue and the assessee's response regarding the alleged property sale transaction. Assessee's Contention: The assessee argued that she had not disclosed the sale transaction because no such transaction occurred, and she requested the sale deed and Power of Attorney to substantiate her claim. The assessee's representative, Shri P. C. Parwal, CA, likely intended to challenge the basis of the reassessment and the Revenue's information. Revenue's Contention: The Revenue's representative, Mrs. Arti Rawat, ACIT, contended that information available with the department indicated the assessee had sold an immovable property for Rs. 1.11 crores, with her share being Rs. 27,75,000, which was not disclosed by the assessee. This formed the basis for reopening the assessment.

Which sections of the Income-tax Act were involved?

Section 147,Section 148,Section 144B

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, ‘SMC’ BENCH, JAIPUR

Before: Smt. Annapurna Gupta & Shri T. R. Senthil Kumar

For Appellant: Shri P. C. Parwal, CA

PER : T. R. SENTHIL KUMAR, JUDICIAL MEMBER:- This appeal is filed by the assessee as against the appellate order dated 30.12.2025 passed by Commissioner of Income Tax (Appeal), National Faceless Appeal Centre (NFAC), Delhi, arising out of reassessment order passed u/s. 147 r.w.s. 144B of the Income Tax Act, 1961 (hereinafter referred to as ‘the Act’) relating to Asst. Year 2016-17. I.T.A No. 98/JPR/2026 Page No 2 Anita Mittal

2.

Brief facts of the case are that the assessee is an individual, filed her return of income for the assessment year 2016-17 on 10.03.2017 declaring to

The order continues below.

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