RAJMATA KAVITESHWARI DEVI,SATNA vs. INCOMETAX OFFICER , SATNA

ITA 107/JAB/2024Status: DisposedITAT Jabalpur12 March 2026AY 2014-15Bench: SHRI KUL BHARAT (Vice President), SHRI ANADEE NATH MISSHRA (Accountant Member)1 pages
AI SummaryPartly Allowed

What did the Tribunal hold?

The Tribunal held that the delay in filing the appeal before the CIT(A) was due to sufficient cause, and the CIT(A) erred in not condoning it. On merits, the Tribunal found that the addition was not clearly explained and lacked proper reasoning, thus restoring the issue to the AO for fresh reference to the DVO and a de novo assessment.

What were the facts?

The assessee's assessment for AY 2014-15 was completed ex parte at Rs. 1,54,80,000/- based on AIR information regarding property sale. The AO referred to DVO for valuation, but the assessee did not respond to DVO notices. The assessee's revision petition was dismissed, and subsequent attempts to withdraw it led to the restoration of the ex parte assessment order.

What were the issues?

Whether the delay in filing the appeal before the CIT(A) was sufficiently excused. Whether the addition made by the AO based on DVO's valuation, without proper explanation or deduction for cost of acquisition, was justified.

Which sections of the Income-tax Act were involved?

Section 144,Section 147,Section 264,Section 254,Section 142A(6),Section 148,Section 153(2),Section 2(23C),Section 264(4),Section 249(2),Section 249(3)

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, JABALPUR BENCH “DB”, JABALPUR

Before: SHRI KUL BHARAT & SHRI ANADEE NATH MISSHRA

For Appellant: Shri Sapan Usrethe, Advocate

(A)

This appeal vide I.T.A. No.107/JAB/2024 has been filed by the assessee for assessment year 2014-15 against impugned appellate order dated 16.04.2024 (DIN & Order No.ITBA/NFAC/S/250/2024- 25/1064133918(1) of Commissioner of Income Tax (Appeals) [“CIT(A)” for short]. (B)

In this case, assessment order dated 05.12.2018 was passed ex parte qua appellant assessee u/s 144 of the Income Tax Act, 1961 (“Act”, for short). In the aforesaid assessment order, the assessee’s total income was assessed at Rs.1,54,80,000/- on the basis of information received in Annual Information Returns (“AIR”, for short) received by the Income Tax Department from various a

The order continues below.

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