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Facts
The assessee, Taxi Operators Union, challenged an assessment order where an addition of Rs. 39.80 Lacs was made for cash deposits under a best judgment assessment. The CIT(A) confirmed this addition. The assessee sought condonation of a 240-day delay in filing the appeal, citing changes in union administration.
Held
The tribunal condoned the delay, admitted the appeal, and set aside the CIT(A)'s order. The matter was restored to the Assessing Officer for a de novo assessment, granting the assessee another opportunity to present its case.
Key Issues
The key legal issues were the condonation of delay in filing the appeal and the validity of the best judgment assessment and the addition made for cash deposits without providing adequate opportunity to the assessee.
Sections Cited
Section 144, Section 147
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Income Tax Appellate Tribunal, “DB” BENCH, AMRITSAR
Before: HON’BLE SHRI MANOJ KUMAR AGGARWAL, AM & SHRI UDAYAN DAS GUPTA, JM
(िनधा�रण वष� / Assessment Year: 2012-13) Taxi Operators Union ITO Ward –1(3) Railway Station (Jammu) Aaykar Bhawan बनाम/ C/o Shri P.N. Arora (Advocate) Rail head complex Vs. 3rd Floor, SRK Mall, 14-Kennedy Avenue Panama Chowk Mall Road, Amritsar (Punjab)-143001 Jammu - 180012 �थायीलेखासं./जीआइआरसं./PAN/GIR No. AABAT-4171-F (अपीलाथ�/Appellant) : (��थ� / Respondent) अपीलाथ�कीओरसे/ Appellant by : Sh. P. N. Arora (Advocate)- Ld. AR ��थ�कीओरसे/Respondent by : Sh. Charan Dass (Addl. CIT) - Ld. Sr. DR सुनवाईकीतारीख/Date of Hearing : 02-02-2026 घोषणाकीतारीख /Date of Pronouncement 03-02-2026 : आदेश / O R D E R Manoj Kumar Aggarwal (Accountant Member) 1. Aforesaid appeal by assessee for Assessment Year (AY) 2012- 13 arises out of an order of learned Commissioner of Income Tax (Appeals), NFAC dated 29-05-2024 in the matter of an assessment framed by Ld. AO u/s 144 / 147 on 03-12-2019.
The registry has noted delay of 240 days in the appeal, the condonation of which has been sought by the Assessee on the