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Facts
The assessee's appeal pertains to an assessment order passed under section 147 r.w.s. 144 of the Income-tax Act, 1961, where credit entries in the bank account were treated as unaccounted business income. The Commissioner of Income-tax (Appeals) had set aside the assessment order for de novo adjudication.
Held
The Tribunal condoned the 142-day delay in filing the appeal, referring to judicial precedents on sufficient cause. The tribunal also noted that the ground regarding the invalidity of reassessment proceedings due to lack of proper sanction under section 151 was raised for the first time. Considering the matter was set aside by the CIT(A), this ground was allowed for statistical purposes.
Key Issues
Validity of reassessment proceedings initiated without proper sanction under Section 151; condonation of delay in filing appeal.
Sections Cited
147, 148, 144, 151, 144B
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Before: SHRI ANIKESH BANERJEE & SHRI PRABHASH SHANKAR
PER PRABHASH SHANKAR [A.M.] :- The present appeal arising from the appellate order dated 20.02.2025 is filed by the assessee against the order passed by the Learned Commissioner of Income-tax (Appeals)/National Faceless Appeal Centre, Delhi [hereinafter referred to as “CIT(A)