INCOME TAX OFFICER-1(2), RAIPUR vs. KANHA GRAIN PROCESS, RAIPUR

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ITA 260/RPR/2025Status: DisposedITAT Raipur01 January 2026AY 2015-16Bench: SHRI R. K. PANDA (Vice President), SHRI PARTHA SARATHI CHAUDHURY (Judicial Member)12 pages
AI SummaryDismissed

What did the Tribunal hold?

The Tribunal held that the reassessment proceedings were bad in law, following the concession made by the Revenue before the Supreme Court. The Revenue had agreed to drop all notices issued under Section 148 after April 1, 2021, for AY 2015-16.

What were the facts?

The Revenue appealed against an order of the CIT(A) which quashed reassessment proceedings initiated for AY 2015-16. The reassessment was based on alleged bogus purchases, with notices issued under Section 148 on 30.06.2021 and later on 23.07.2022.

What were the issues?

The primary issue was the validity of reassessment notices issued for AY 2015-16 after April 1, 2021, in light of a Supreme Court concession regarding the Taxation and other Laws (Relaxation and Amendment of Certain Provisions) Act, 2020.

Which sections of the Income-tax Act were involved?

Section 148,Section 147,Section 144B,Section 69C,Section 143(3),Section 148A(d)

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Income Tax Appellate Tribunal, RAIPUR BENCH, RAIPUR

Before: SHRI R. K. PANDA & SHRI PARTHA SARATHI CHAUDHURY

For Appellant: Shri Sunil Kumar Agrawal
For Respondent: Dr. Priyanka Patel, Sr. DR

आदेश की प्रतितिति अग्रेतिि/Copy of the Order is forwarded to: 1. अपील र्थी / The Appellant; 2. प्रत्यर्थी / The Respondent 3. The concerned Pr.CIT, Raipur 4. DR, ITAT, Raipur Bench 5. ग र्ड फ ईल / Guard file. आदेशानुसार/ BY ORDER, // True Copy // Assistant Registrar आयकर अपीलीय अदिकरण ,पुणे / ITAT, Pune

S.No. Details Date Initials Designation 1 Draft dictated on 09.12.2025 Sr. PS/PS 2 Draft placed before author 10.12.2025 Sr. PS/PS Draft proposed & placed before the 3 JM/AM Second Member Draft discussed/approved by Second 4 AM/AM Member 5 Approved Draft comes to the Sr. PS/PS Sr. PS/PS 6 Kept for pronouncement on Sr. PS/PS 7 Date of uploading of Order Sr. PS/PS 8 File sent to Bench Clerk Sr. PS/PS Date on which the file goes to the Office 9 Superintendent 10 Date on which file goes to the A.R. 11 Date of Dispatch of order

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