Facts
The assessee firm's appeals were against orders related to reassessment proceedings under Section 147. The AO initiated proceedings based on information that the assessee deposited a large sum but did not file a return, assessing it as unexplained money. The CIT(A) partly allowed the appeals by setting aside the matter to the AO to verify if the income was already offered to tax by a partner.
Held
The Tribunal held that the assessee firm participated in the reassessment proceedings, thus waiving any objection regarding the validity of the notice under Section 148, as per Section 292BB. Regarding the second appeal, the Tribunal followed the view that the enhanced tax rate under Section 115BBE was applicable from AY 2018-19, not AY 2017-18.
Key Issues
Whether the reassessment proceedings were validly initiated and whether the special tax rate under Section 115BBE was applicable for AY 2017-18.
Sections Cited
147, 144, 144B, 154, 148, 69A, 251(1)(a), 292BB, 115BBE, 139, 68, 69, 69B, 69C, 69D
AI-generated summary — verify with the full judgment below
Income Tax Appellate Tribunal, Hyderabad ‘A’ Bench, Hyderabad
आदेशक���त�ल�पअ�े�षत/ Copy of the order forwarded to:- 1. �नधा�रती/The : Navadurga Transport Company, 15-7-279/3, Muslimjungbridge, Begum Bazar, Assessee Hyderabad, Telangana-500012. 2. राज�व/ : Income Tax Officer, Ward-7(1), O/o, ITO, The Ward-7(1), Signature Towers, Hyderabad, Revenue Telangana. 3. The Principal Commissioner of Income Tax, Hyderabad. 4. �वभागीय��त�न�ध, आयकरअपील�यअ�धकरण /DR,ITAT, Hyderabad. 5. The Commissioner of Income Tax 6. गाड�फ़ाईल / Guard file
आदेशानुसार / BY ORDER
Sr. Private Secretary ITAT, Hyderabad.