ACIT, NUNGAMBAKKAM vs. INTEGRATED SERVICE POINT LIMITED, ANNA NAGAR

ITA 1876/CHNY/2025Status: DisposedITAT Chennai30 December 2025AY 2019-2067 pages
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What did the Tribunal hold?

The Tribunal held that the approval for reassessment proceedings for AY 2016-17 was not granted by the competent authority as required by Section 151(ii) of the Income Tax Act. Therefore, the assessment order for that year was invalid.

What were the facts?

During a search operation, unaccounted transactions were found in an Excel sheet on a hard disk. The assessee claimed these transactions were for business expediency and cash expenses, while the revenue treated them as income. A key issue was the validity of the approval for reassessment proceedings.

What were the issues?

The primary issue was whether the approval for reassessment proceedings was obtained from the correct authority as per Section 151(ii), and if not, whether the assessment order was void ab initio. Another issue involved the treatment of transactions found in seized documents.

Which sections of the Income-tax Act were involved?

Section 151,Section 148,Section 147

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Cases cited in this judgment(11)Show list

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आयकर अपीलीय अधिकरण 'सी' न्यायपीठ, चेन्नई। IN THE INCOME TAX APPELLATE TRIBUNAL 'C' BENCH: CHENNAΙ मप्सनीय श्री मनु कुमार गिरि, न्यायिक सदस्य एवं मप्सनीय श्री जगदीश, लेख सदस्य के समक्ष BEFORE HON’BLE SHRI MANU KUMAR GIRI, JUDICIAL MEMBER AND SHRI HON'BLE JAGADISH, ACCOUNTANT MEMBER आयकर अपील सं./ ITA Nos.1881, 1882 & 1883/Chny/2025 निर्धारण वर्ष / Assessment Years: 2016-17, 2019-20 & 2022-23 The Dy./Asst. Commissioner of Income Tax, Central Circle-2(4), Chennai. 6C, 6th Floor, Gaiety Palace I/L, Blackers Road, Anna Road H.O., Chennai - 600 002. PAN: AAACI 9527P (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) आयकर अपील सं./ ITA Nos.1874, 1876 & 1879/Chny/2025 निर्धारण वर्ष / Assessment Years: 2016-17, 2019-20 & 2022-23 The Dy./Asst. Commissioner of Income Tax, Central Circle-2(4), 6C, 6th Floor, Gaiety Palace I/L, Blackers Road, Anna Road H.O., Chennai - 600 002. PAN: AAACI 9527P (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) अपीलार्थी की ओर से/ Assessee by : Mr. Y. Sridhar, FCA प्रत्यर्थी की ओर से /Revenue by : Mr.

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