SUNKARA KOTIPALLI NAIDU ,VISAKHAPATNAM vs. THE INCOME TAX OFFICER, WARD (INTERNATIONAL TAXATION), VISAKHAPATNAM

ITA 299/VIZ/2024Status: DisposedITAT Visakhapatnam07 March 2025AY 2016-17Bench: SHRI K. NARASIMHA CHARY, HON'BLE (Judicial Member), SHRI S BALAKRISHNAN, HON'BLE (Accountant Member)6 pages
AI SummaryRemanded

What did the Tribunal hold?

The Tribunal admitted the additional evidences presented by the assessee (confirmation letters and bank statements) as they were deemed necessary for a fair adjudication. The case was remitted back to the Assessing Officer to re-examine these evidences and complete the assessment de novo in accordance with law.

What were the facts?

The assessee, a non-resident individual, did not file an income tax return. The AO initiated reassessment proceedings under Section 147 based on NMS data revealing significant immovable property purchases. The DRP rejected the assessee's objections against an addition of Rs. 59,05,450/- due to a filing delay, leading to the current appeal before the Tribunal.

What were the issues?

Whether the DRP was justified in rejecting the assessee's objections due to a delay, and if additional evidence should be admitted to decide the unexplained investment additions under Section 69 on merits.

Which sections of the Income-tax Act were involved?

Section 147,Section 144C(3),Section 148,Section 148A(d),Section 142(1),Section 144(5),Section 69

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Income Tax Appellate Tribunal, VISAKHAPATNAM “DIVISION” BENCH, VISAKHAPATNAM

Before: SHRI K. NARASIMHA CHARY, HON’BLE & SHRI S BALAKRISHNAN, HON’BLE

For Appellant: Shri GVN Hari, Advocate
For Respondent: Dr. Satyasai Rath, CIT(DR)
Pronounced: 07.03.2025

PER SHRI S BALAKRISHNAN, ACCOUNTANT MEMBER:

1.

This appeal is Filed by the assessee against the final assessment order passed under section 147 r.w.s. 144C(3) of Income Tax Act, 1961 (in

The order continues below.

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