RAM RATAN JANGIR,AMER vs. INCOME TAX OFFICER, WARD -7(2), JAIPUR

ITA 550/JPR/2024Status: DisposedITAT Jaipur22 July 2024AY 2013-14Bench: DR. S. SEETHALAKSHMI (Judicial Member)1 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that the reassessment proceedings were initiated based on the same set of records already examined during the original scrutiny assessment. This constituted a change of opinion by the Assessing Officer, making the reassessment invalid.

What were the facts?

The assessee's original assessment for AY 2013-14 was completed under section 143(3). Later, reassessment proceedings under section 147 were initiated based on information that interest on unsecured loans was claimed wrongly. The reassessment led to additions and disallowances.

What were the issues?

The primary issue was the validity of reassessment proceedings initiated under Section 147 when the grounds for reopening were already considered and examined during the original scrutiny assessment under Section 143(3).

Which sections of the Income-tax Act were involved?

Section 147,Section 143(3),Section 148

AI-generated summary — verify with the full judgment below

Cases cited in this judgment(18)Show list

Detected automatically from the text. Citations are also linked where they appear in the judgment. The count shows how many other judgments on BharatTax rely on the same authority.

Income Tax Appellate Tribunal, JAIPUR BENCHES,”SMC” JAIPUR

Before: DR. S. SEETHALAKSHMI, JM & SHRI RATHOD KAMLESH JAYANTBHAI, vk;dj vihy la-@ITA No. 550/JP/2024

For Appellant: CA jktLo dh vksj ls@
Hearing: 03/07/2024Pronounced: 22/07/2024

PER: RATHOD KAMLESH JAYANTBHAI, AM

This appeal filed by assessee is arising out of the order of the Commissioner of Income Tax, Appeal, Kolkata dated 20/03/2024 [here in after (ld. CIT(A)] for assessment year 2013-14 which in turn arise from the order dated 30.03.2016 passed under section 143(3) of the Income Tax Act, by DCIT, Circle-07, Jaipur.

2.

In this appeal, the assessee has raised following grounds: -

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.

Create a free accountSign in

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 →