SRI.PARAYARUKANDY VETTATH GANGADHARAN,CALICUT vs. THE DCIT CIRCLE-1(1), CALICUT

ITA 158/COCH/2023Status: DisposedITAT Cochin29 April 2024AY 2008-09Bench: Shri Sanjay Arora (Accountant Member), Ms. Kavitha Rajagopal (Judicial Member)4 pages
AI SummaryDismissed

What did the Tribunal hold?

The Tribunal held that the impugned assessments were made in consequence of a finding or direction by the Tribunal in the case of a firm in which the assessee was a partner. Therefore, the extended time limit under section 153(3)(ii) read with section 150 of the Act was applicable, making the assessments in time.

What were the facts?

The assessee's appeals contested assessments made under section 147 read with section 143(3) of the Income-tax Act, 1961. The core issue was the validity of these assessments, which the assessee argued were time-barred.

What were the issues?

The primary issue was whether the reassessment proceedings initiated against the assessee were within the prescribed time limit, considering the prior orders of the Tribunal in the case of a firm where the assessee was a partner.

Which sections of the Income-tax Act were involved?

Section 147,Section 143(3),Section 150,Section 153(3)

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Income Tax Appellate Tribunal, COCHIN BENCH, COCHIN

Before: Shri Sanjay Arora & Ms. Kavitha Rajagopal

For Appellant: Shri Suresh Kumar C., CA
For Respondent: Smt. J.M. Jamuna Devi, Sr. DR
Hearing: 06.02.2024Pronounced: 29.04.2024

Per Sanjay Arora, AM: This is a set of two Appeals by the Assessee directed against the dismissal of his appeals contesting his assessments under section 147 read with sec.143(3) of the Income-tax Act, 1961 (the Act) dated 04.03.2015 for assessment years (AYs.) 2005- 2006 & 2008-09, by the Commissioner of Income-tax (Appeals) [CIT(A)] vide his orders of even date (05.01.2023). The appeals raising a common issue, were heard together, and are being disposed of per a common order for the sake of convenience.

2.

At the very outset, it was a common contention by the parties that the subject matter of the instant appeal is the same as that of the assesse

The order continues below.

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