RAJEEV KUMAR HOUSE NO 4 GALI NO 1 AMARKOT KRISHNA NAGAR ,AMRITSAR vs. INCOME TAX OFFICER, WARD 4(4) AMRITSAR PUNJAB, INCOME TAX OFFICER

ITA 359/ASR/2023Status: DisposedITAT Amritsar17 January 2025Bench: SH. UDAYAN DASGUPTA, JUDICIAL MEMBER AND SH. KRINWANT SAHAY (Accountant Member)1 pages
AI SummaryPartly Allowed

What did the Tribunal hold?

The Tribunal noted that the explanations and documentary evidence regarding the cash deposits were submitted for the first time before it. The Tribunal found that these explanations were not properly supported by necessary documents before the AO and CIT(A). Therefore, the matter was set aside to the AO for examination and verification of the new documentary evidence.

What were the facts?

The assessee deposited Rs. 23,51,355/- in cash in bank accounts during FY 2011-12. The Assessing Officer (AO) issued a notice under Section 148 for reopening the assessment. The assessee failed to provide satisfactory explanation or documentary evidence regarding the source of these deposits.

What were the issues?

Whether the cash deposits in the bank account were explained and substantiated with documentary evidence, and whether the notices issued for reopening the assessment were properly served.

Which sections of the Income-tax Act were involved?

Section 250,Section 147,Section 144,Section 136(6),Section 148,Section 142(1)

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, AMRITSAR BENCH, AMRITSAR

Before: SH. UDAYAN DASGUPTA & SH. KRINWANT SAHAY

For Appellant: Adv. :
Hearing: 23.12.2024Pronounced: 17.01.2025

Per Udayan Dasgupta, J.M.:

This appeal is filed by the assessee against the order of the ld. CIT(A) National

Faceless Appeal Centre (NFAC) Delhi dated 18.10.2023 passed u/s 250 of the Income Tax Act, 1961 which has emanated from the order of the ITO, Ward 4(4), Amritsar passed u/s 147/144 of the I.T. Act, 1961 dated 12.12.2019. 2 Rajeev Kumar v. ITO

2.

The grounds of appeal are in essay form and as such not reproduced in the order.

3.

Ground Nos. 1, 2, 3 and 8 relates to the issue of non-service of notice u/s 148

and ground nos. 4 & 5 relates to the issue of non-supply of copy of recorded reasons

and ground nos. 6 and 7

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.

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 →