SMT. MANDA THETE,NAGPUR vs. ASST. COMMISSIONER OF INCOME TAX, JABALPUR

ITA 47/JAB/2025Status: DisposedITAT Jabalpur19 February 2026AY 2012-13Bench: SHRI ANADEE NATH MISSHRA (Accountant Member)3 pages
AI SummaryPartly Allowed

What did the Tribunal hold?

The ITAT set aside the CIT(A)'s order and remanded the issues back to the Assessing Officer for a de novo assessment. The AO is directed to pass a fresh order after providing the assessee a reasonable opportunity to present facts and evidence.

What were the facts?

The assessee filed a return of income, which was assessed under Section 143(3). Subsequently, the AO initiated reassessment proceedings under Section 148 regarding unsecured loans, which the CIT(A) confirmed. The assessee appealed to the ITAT.

What were the issues?

The key legal issues are the validity of the reassessment proceedings under Section 148 and the treatment of unsecured loans as unexplained, particularly regarding the proof of identity, creditworthiness, and genuineness.

Which sections of the Income-tax Act were involved?

Section 143(3),Section 148

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, JABALPUR BENCH ‘SMC’, JABALPUR

Before: SHRI ANADEE NATH MISSHRA

(A) This appeal vide I.T.A. No.47/JAB/2025 has been filed by the assessee for assessment year 2012-13 against impugned appellate order dated 03/01/2025 (DIN & Order No.ITBA/NFAC/S/250/2024- 25/1071862626(1) of National Faceless Appeal Centre [“NFAC” for short]. Grounds of appeal are as under:- “1. That the order passed us 250 by the CIT(Appeals) faceless is invalid and unlawful on the facts and circumstances of the case. Assessment Year: 2012-13 2

2.

That the CIT Appeals faceless erred in confirming the action of A.O. us 148 notice dated 30.03.2019 in confirming the reasons recorded for treating the unsecured loans for Rs. 3140045 which has already been proved and accepted by the A

The order continues below.

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