DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-4, JAIPUR, JAIPUR vs. VIMAL PARWAL, JAIPUR
What did the Tribunal hold?
The Tribunal held that the reassessment proceedings initiated under Section 148 were legally untenable. It found that the materials forming the basis of reassessment were seized during search proceedings on another person, thus Section 153C should have been invoked instead of Section 147/148.
What were the facts?
A search action on the Ramesh Manihar Group revealed information about cash loans and brokerage not offered for taxation. The assessee was found to be associated with this group, having paid cash loans from undisclosed income and received interest. The Assessing Officer (AO) issued notices under Section 148 based on this information.
What were the issues?
Whether reassessment proceedings initiated under Section 148 were valid when the information was derived from a search on another entity, and if Section 153C was the appropriate provision to invoke.
Which sections of the Income-tax Act were involved?
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Income Tax Appellate Tribunal, JAIPUR BENCHES,”A” JAIPUR
Before: DR. S. SEETHALAKSHMI, JM & SHRI GAGAN GOYAL, AM vk;dj vihy la-@ITA No. 1230 & 1231/JPR/2024
PER DR. S. SEETHALAKSHMI, J.M.
These are appea
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More judgments on Section 148
- ACIT Central Bilaspur, Bilaspur vs Arun Kumar Agrawal, SaktiITSSA 26/RPR/2025[2018-19]Status: Disposed21 Oct 2026AY 2018-19
- Vinod Agrawal, Kawardha vs Assisstant Commissioner of Income Tax…ITA 666/RPR/2026[2019-20]Status: Heard21 Oct 2026AY 2019-20
- Sar Business Tradelink Private Limited… vs Income Tax Officer, Ward - 1(2), RaipurITA 599/RPR/2026[2014-15]Status: Heard21 Oct 2026AY 2014-15
- Neo Incorporation, Rajkot vs DCIT Circle- 1(2), RajkotITA 471/RJT/2026[2012-2013]Status: Disposed21 Oct 2026AY 2012-2013
- Adj Agri International LLP, Rajkot vs The Income Tax Officer, Ward-1(1)(1), RajkotITA 1198/RJT/2026[2018-19]Status: Disposed21 Oct 2026AY 2018-19
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