SHRI ABDUL AZIZ DAR,BARAZULA vs. INCOME TAX OFFICER WARD-1, SRINAGAR

ITA 440/ASR/2024Status: DisposedITAT Amritsar06 April 2026AY 2014-156 pages
AI SummaryRemanded

What did the Tribunal hold?

The Tribunal found that the assessee had not presented arguments on merits at any stage and had raised new grounds regarding the limitation of the notice under section 148. Since the assessment order lacked a date-wise sequence of events for proper calculation and this issue was not adjudicated by the lower authorities, the matter was remanded.

What were the facts?

The assessee filed a return disclosing income of Rs. 2.47 lakhs. Later, based on information about property purchase of Rs. 75.60 lakhs, reassessment proceedings under section 147 were initiated. The assessment was completed ex-parte at Rs. 5.71 crores due to non-response to notices. The first appeal was dismissed for non-representation on multiple dates.

What were the issues?

Whether the notice under section 148 was issued within the limitation period, and whether the assessee was provided adequate opportunity of being heard.

Which sections of the Income-tax Act were involved?

Section 139,Section 147,Section 144,Section 148,Section 148A,Section 69,Section 69A,Section 250,Section 142(1)

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Cases cited in this judgment(2)Show list

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Income Tax Appellate Tribunal, AMRITSAR BENCH, AMRITSAR.

Before: SH. UDAYAN DASGUPTA & SH. KRINWANT SAHAY

Pronounced: 06.04.2026

Per: Udayan Dasgupta, J.M.: This appeal is filed by the assessee against the order of ld. CIT (A), NFAC, Delhi, passed u/s 250 of the Act, 1961 vide order dated 07.06.2024 which has emanated from the order of AO, passed u/s 147 r.w.s. 144 of the Act, vide order dated 11.05.2023. 2. Condonation of Delay: This appeal is filed vide speed post from Srinagar which has reached the office of the tribunal at Amritsar, belatedly by two days, on 2 Assessment Year: 2014-15

8th august, 2024, the nominal delay in this case is condoned and the appeal admitted for hearing on merits.

3.

There are eight grounds taken by the assesee in form 36, but the main grievance pertains to disp

The order continues below.

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