TEJENDER PAL SINGH SAHNI,KOTA vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, KOTA

ITA 1147/JPR/2024Status: DisposedITAT Jaipur10 January 2025AY 2014-15Bench: Dr. S. SEETHALAKSHMI (Judicial Member), SHRI GAGAN GOYAL (Accountant Member)28 pages
AI SummaryPartly Allowed

What did the Tribunal hold?

The Tribunal held that the AO failed to properly examine the gift transactions despite all relevant material being on record. The Tribunal found the donor to be a person of means and accepted the assessee's contentions regarding the gifts.

What were the facts?

The assessee's case was subject to a search and seizure operation, leading to reassessment. The ITAT had previously set aside the matter for verification of gift sources. The Assessing Officer (AO) made additions under Section 69, which were confirmed by the CIT(A).

What were the issues?

Whether the additions made under Section 69 for unexplained investment were justified, considering the verification of gift sources as directed by the ITAT. Whether the assessment order was time-barred and if the AO exceeded jurisdiction.

Which sections of the Income-tax Act were involved?

Section 69,Section 144,Section 153A,Section 142(1),Section 254

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, JAIPUR BENCH “SMC”, JAIPUR

Before: Dr. S. SEETHALAKSHMI & SHRI GAGAN GOYAL

For Appellant: Mr. C. M. Birla, CA, Ld. AR
For Respondent: Mr. Gautam Singh Choudhary, JCIT, Ld. DR
Hearing: 07/01/2025Pronounced: 10/01/2025

PER GAGAN GOYAL, A.M: These two appeals by assessee are directed against the order of Ld. CIT (A), Udaipur-2 dated 28.08.2024 passed u/s. 250 of the Income Tax Act, 1961 (in short ‘the Act’) for A.Ys. 2014-15 & 2016-17. In ITA No. 1147/JP/2024, the assessee has raised the following grounds of appeal:

1.

That as Assessment Order u/s. 144 of the Act dated 22/06/2021 is time barred u/s. 153(3) of the Act, it is prayed that same be quashed.

2.

That on account of non-compliance of notice u/s. 143(2) of the Act dated 20/04/2021 fixing hearing on 23/04/2021 Assessment Order u/s. 144/254(2) of the Act is passed on 22/06/2021. As the ord

The order continues below.

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