M/S LORGAN LIFESTYLE LTD.,PUNE vs. ITO, WARD14(4), PUNE, PUNE

ITA 215/PUN/2025Status: DisposedITAT Pune03 September 2025AY 2015-16Bench: DR.MANISH BORAD, ACCOUNTANT MEMBER AND MS.ASTHA CHANDRA (Judicial Member)12 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal condoned the delay in filing the appeal. It held that the reassessment proceedings were bad in law because the AO made an addition on account of bad debts, which was not part of the reasons recorded for reopening the assessment, violating the principle laid down in CIT vs. Jet Airways (I) Ltd.

What were the facts?

The assessee company filed an appeal before the ITAT with a significant delay due to financial difficulties and issues with email communication. The Assessing Officer (AO) initiated reassessment proceedings based on reasons like cash deposits and vehicle purchases, but the addition was made on account of bad debts, which were not part of the initial reasons.

What were the issues?

Whether reassessment proceedings are valid when the addition made is not based on the reasons recorded for reopening the assessment. Whether the delay in filing the appeal can be condoned due to reasonable cause.

Which sections of the Income-tax Act were involved?

Section 147,Section 148,Section 143(3),Section 250

AI-generated summary — verify with the full judgment below

Cases cited in this judgment(8)Show list

Detected automatically from the text. Citations are also linked where they appear in the judgment. The count shows how many other judgments on BharatTax rely on the same authority.

Income Tax Appellate Tribunal, PUNE BENCHES “A”, PUNE

Before: DR.MANISH BORAD & MS.ASTHA CHANDRA

For Appellant: Shri B S Rajpurohit
For Respondent: Shri Amol Khairnar
Hearing: 21.07.2025Pronounced: 03.09.2025

PER DR. MANISH BORAD, ACCOUNTANT MEMBER :

The captioned appeal at the instance of assessee pertaining to A.Y. 2015-16 is directed against the order dated 24.05.2023 of National Faceless Appeal Centre (NFAC), Delhi passed u/s.250 of the Income-tax Act, 1961 (hereinafter also called ‘the Act’) arising out of Assessment Order dated 30.12.2019 passed u/s.143(3) r.w.s147 of the Act.

2.

Registry has informed that there is delay of 546 days in preferring the instant appeal before this Tribunal. Assessee has filed an affidavit explaining the reasons which led to delay in filing of the appeal. The contents of the said affidavit reads as follows :

The order continues below.

Read the full judgment

A free account opens 10 full judgments a month. Re-reading one you have already opened does not count again.

Create a free accountSign in

See plans and prices

The summary, the parties, the sections and the citations above are open to everyone and always will be. Only the text of the order and the PDF are metered.

More judgments on Section 147

All 49,210 judgments and leading authorities on Section 147 →

Recent GST High Court judgments

Search GST case law →