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“Income-tax Officer”

Chapter I - PreliminarySection 2 - DefinitionsSection 2(25) / Section 1175,006 judgments

The decision most relied on for Income-tax Officer is CIT v. Max India Ltd. (295 ITR 282), cited in 1,162 judgments on BharatTax.

Leading authorities on Income-tax Officer

CIT v. Max India Ltd.
295 ITR 282 · 2007 · Supreme Court
1,162
citing judgments

Under Section 263, an assessment order is not erroneous and prejudicial to the interest of the revenue merely because the Principal Commissioner disagrees with the Assessing Officer's (AO) view, particularly if the AO has adopted one of two permissible views in law, unless that view is completely unsustainable. If due inquiries were made, the AO's order does not become erroneous solely because the fact of inquiries was not recorded.

Dhakeshwari Cotton Mills Ltd. v. CIT
26 ITR 775 · 1954 · Supreme Court
1,061
citing judgments

Corroborative evidence is essential to support evidence found on third-party premises, and an assessment cannot be based on suspicion, surmises, or conjecture.

Kale Khan Mohammad Hanif v. CIT
50 ITR 1 · 1963 · Supreme Court
581
citing judgments

The assessee bears the onus of proving the source and nature of any sum of money or receipt found to have been received by them. If the assessee fails to satisfactorily explain the receipt, the Income-tax Officer is entitled to treat it as taxable income.

Union of India v. Ashish Agarwal
444 ITR 1 · 2022 · Supreme Court
524
citing judgments

Notices issued under the unamended Section 148 of the Income-tax Act between April 1, 2021, and May 4, 2022, must be treated as notices issued under the new Section 148A(b) of the amended law. This requires the Assessing Officer to follow the procedure prescribed under the amended reassessment provisions, including issuing an order under Section 148A(d) before a fresh notice under Section 148.

CIT v. Kanpur Coal Syndicate
53 ITR 225 · 1964 · Supreme Court
359
citing judgments

The Commissioner (Appeals) holds plenary powers when disposing of an appeal, with their scope being coterminous with the Assessing Officer. This allows the CIT(A) to exercise all powers of the AO, including admitting additional evidence and redetermining income.

222 Taxman 15 (Gujarat)(MAG.), Principal Commissioner of Income-tax-4 v. G & G Pharma India Ltd.
384 ITR 147 · 2016 · High Court
274
citing judgments

An assessment can be reopened if there is tangible material indicating escapement of income, demonstrating a live link between the material and the reasons recorded for reopening. The Assessing Officer must apply their mind to the material facts, and the sanction under section 151 should not be based on borrowed satisfaction.

Paul Mathews & Sons. v. CIT
263 ITR 101 · 2003 · High Court
266
citing judgments

A statement recorded under Section 133A of the Income-tax Act has no evidentiary value because Section 133A does not empower an Income-tax Officer to examine any person on oath.

Navnitlal C. Javeri v. K.K. Sen
56 ITR 198 · 1965 · Supreme Court
230
citing judgments

The Supreme Court holds that circulars issued by the Central Board of Direct Taxes (CBDT) are binding on all officers and persons employed in the execution of the Income-tax Act. These circulars are binding even if they deviate from the provisions of the Act, particularly when issued to relieve hardships.

Judgments citing Income-tax Officer

The Cuddalore District Central Co-Op. Bank Ltd., Cuddalore vs. ACIT, Circle-1, Cuddalore

In the result, appeal filed by the assessee is allowed for statistical purpose

ITA 2669/CHNY/2024[2018-19]Status: DisposedITAT Chennai09 Jan 2025AY 2018-19

Bench: SHRI MANOJ KUMAR AGGARWAL (Accountant Member), SHRI MANU KUMAR GIRI (Judicial Member)

For Appellant: Shri G. Akash , Advocate for Shri. KFor Respondent: Ms. D. Komali Krishna, CIT
Section 250

National Faceless Appeal Centre (NFAC), Delhi in order No.ITBA/NFAC/S/250/2024-25/1068009690(1) dated 27.08.2024. The assessment was framed by the Additional/Joint/Deputy/Assistant Commissioner of Income Tax/ Income-tax Officer, National e-Assessment Centre, Delhi u/s. 250 of the Income Tax Act, 1961 (hereinafter the ‘Act’) for the assessment year 2018-19 vide order

Vasna Rathod Dudh Utpadak Sahakari Mandali, Gandhinagar vs. The Income Tax Officer, Ward-1 (Previously Ward-4), Gandhinagar

In the result, the appeal of the assessee is allowed

ITA 1829/AHD/2024[2017-18]Status: DisposedITAT Ahmedabad08 Jan 2025AY 2017-18

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal

For Appellant: Shri P. F. Jain, A.RFor Respondent: Shri V K Mangla, Sr. DR
Section 80Section 80PSection 80P(2)(a)Section 80P(2)(b)Section 80P(2)(c)

reflected in the computation of income submitted by the assessee. In the case of Venus Parkland Co-Op. Housing Service Society Ltd. vs. Income-tax Officer [2024] 166 taxmann.com 673 (Ahmedabad - Trib.)/[2024] 209 ITD 229 (Ahmedabad - Trib.)[07-08- 2024], the Tribunal held that where assessee, a housing ... deduction under section 80P(2)(c)(ii) of the Act. In the case of Baroda Citizen Community Co-op. Credit Society Ltd. vs. Income-tax Officer [2022] 134 taxmann.com 290 (Ahmedabad - Trib.)/[2022] 193 ITD 113 (Ahmedabad - Trib.)[01-12-2021], the Tribunal held that in case of co- operative

The ITO, (Exemptions), Ward-2, Ahmedabad vs. The Gujarat Institute of Housing & Estate Developers, Ahmedabad

In the result, the appeal of the Department is allowed

ITA 1022/AHD/2017[2011-12]Status: DisposedITAT Ahmedabad08 Jan 2025AY 2011-12

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal

For Appellant: Shri Waghe Prasad Rao, Sr. DRFor Respondent: Shri S. N. Soparkar, Sr. Advocate
Section 11Section 12ASection 25Section 271(1)(c)

subject only got clarity vide order of the High Court of the Gujarat in the case of Junagadh Gymkhana vs. Income-tax officer 56 taxmann.com 281 (Gujarat) vide order dated 05.11.2015. Thirdly, the Counsel for the assesseee submitted that Ld. CIT(A) has correctly observed that once the very basis

Reliance Industries Emp Co. Op. Chs, Raigad vs. ITO Ward 4, Panvel

In the result, appeal of the assessee is allowed

ITA 2486/PUN/2024[2020-21]Status: DisposedITAT Pune08 Jan 2025AY 2020-21

Bench: DR.DIPAK P. RIPOTE (Accountant Member), SHRI VINAY BHAMORE (Judicial Member)

Section 250Section 80PSection 80P(2)Section 80P(2)(a)Section 80P(2)(d)

ITAT Pune Bench in the case of Kolhapur District Central Co-op. Bank Kanista Sevakanchi Sahakar Pat Sanstha Ltd. Vs. Income-tax Officer 158 taxmann.com 322 (Pune Tribunal) has held as under : 6 Quote “7………………………..I am of the considered opinion that even the interest income earned by cooperative society

Shobika, K.P.Complex, Tuticorin vs. The Income Tax Officer, Ward-4, Income Tax Office, Tuticorin

In the result, appeal filed by the assessee is allowed for statistical purposes

ITA 2131/CHNY/2024[2017-18]Status: DisposedITAT Chennai08 Jan 2025AY 2017-18

Bench: Shri Aby T. Varkey & Shri Jagadish

For Appellant: Mr. P.M. Kathir, AdvocateFor Respondent: Mr. P.K. Senthil Kumar
Section 143(3)Section 250

order of the Tribunal, the fact-finding authority, that reads thus : "We will straightaway agree with the assessee's submission that the Income-tax Officer had not given to the assessee proper opportunity of being heard." 2. That the assessee could have placed evidence before the first appellate authority ... case, the Tribunal was justified in not setting aside the assessment order in spite of a finding arrived at by it that the Income-tax Officer had not given a proper opportunity of hearing to the assessee?" 4. In our opinion, there can only be one answer to this question

Deputy Commissioner of Income-Tax, Central Circle-2, Patna, C.R. Building vs. Deepshree Properties Pvt. Ltd., Saguna Khagaul Danapur Patna

In the result, the appeal filed by the Revenue is allowed for statistical purposes

ITA 239/PAT/2023[2018-19]Status: DisposedITAT Patna08 Jan 2025AY 2018-19

Bench: SHRI DUVVURU RL REDDY, VICE PRESIDENT SHRI SANJAY AWASTHI (Accountant Member)

Section 133ASection 143(2)Section 143(3)Section 153ASection 153CSection 250Section 69ASection 69C

under sub-section (1), and shall make such amendment if the mistake is brought to its notice by the assessee or the Income-tax Officer: Provided that an amendment which has the effect of enhancing an assessment or reducing a refund or otherwise increasing the liability of the assessee, shall

Ajay Agarwal, Jaipur vs. CIT (It), Delhi-1, CIT(It) Delhi

In the result, the appeal of the assessee is allowed

ITA 637/JPR/2024[2018-19]Status: DisposedITAT Jaipur08 Jan 2025AY 2018-19

Bench: SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member), SHRI NARINDER KUMAR (Judicial Member)

For Appellant: MS Suhani Meharwal, CAFor Respondent: Sh. Arvind Kumar, CIT-DR
Section 129Section 139(1)Section 142(1)Section 143(1)Section 143(2)Section 195Section 263

held that the prerequisite for the exercise of jurisdiction by the Commissioner suo-motu is that the order of the Income-tax Officer is erroneous in so far as it is prejudicial to the interests of the revenue. The Commissioner has to be satisfied of twin conditions, namely ... erroneous; and (ii) it is prejudicial to the interests of the revenue. If one of them is absent - if the order of the Income-tax Officer is erroneous but is not prejudicial to the revenue or if it is not erroneous but is prejudicial to the revenue - recourse cannot

Arun Bhardwaj, Delhi vs. ACIT Circle 1, Jaipur

In the result, appeal of the assessee is allowed

ITA 1190/JPR/2024[2010-2011]Status: DisposedITAT Jaipur08 Jan 2025AY 2010-2011

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI GAGAN GOYAL (Accountant Member)

For Appellant: Shri S.L. Jain, Advocate &For Respondent: Shri Gautam Singh Choudhary, JCIT
Section 139(1)Section 147Section 148Section 234ASection 250

Revenue; the sub- 14 Arun Bhardwaj, Delhi. section contemplated only the transfer of an assessment case for particular year actually pending before an Income-tax Officer; (b) that the petitioner was, therefore, entitled to the benefit of the provisions of section 64(1) and (2) and had the right along ... Division Bench has held (headnote): "In regard to the business income of an assessee it is only the Income-tax Officer having jurisdiction over the place where his business activities are concentrated who would have jurisdiction to assess ; where the assessee has no business it is the place of residence

Savita Goyal, Delhi vs. ITO, Delhi

The appeals are allowed

ITA 2821/DEL/2024[2017-18]Status: DisposedITAT Delhi07 Jan 2025AY 2017-18

Bench: Shri Anubhav Sharma & Shri Krinwant Sahay

For Appellant: Dr. Rakesh Gupta, Advocate &For Respondent: Ms Monika Singh, CIT-DR
Section 153Section 153ASection 153D

distinguishable. human limitations was an issue before Hon’ble Bench. Reliance is placed in the case of Home Finders Housing Ltd. v Income-tax Officer Ward 2(3), Chennai [2018] 93 taxmann.com 371 (Madras) wherein it was held that in case an order is passed without following a prescribed procedure

Madurai Tuticorin Expressways Limited, Hyderabad vs. ACIT., Circle - 5(1), Hyderabad

In the result, all three appeals of the assesssee, i

ITA 1143/HYD/2024[2017-18]Status: DisposedITAT Hyderabad07 Jan 2025AY 2017-18

Bench: SHRI LALIET KUMAR (Judicial Member), SHRI MADHUSUDAN SAWDIA (Accountant Member)

Section 147Section 148Section 148ASection 80PSection 80P(2)(d)

three captioned appeals, i.e., ITA Nos. 1143, 1144 and 1145/Hyd/2025, that reads as under: “1) The notice u/s 148 issued by the Income-Tax Officer, Ward- 1, Warangal is without jurisdiction and, therefore, the consequent assessment made is invalid.” 3. As the assessee, by raising the aforesaid additional ground ... would further observe that the Hon’ble High Court of Jurisdiction in its order in the case of Yashnu Yasasvi Polucherla Vs. Income-tax Officer (2025) 179 taxmann.com 470 (Telangana), had held that as its earlier order in the case of Kankanala Ravindra Reddy Vs. ITO & 2 Others (supra

Viswanadh Kandula, Hyderabad vs. DCIT., Circle-6(1), Hyderabad

In the result, appeals of the assessee for the A

ITA 1085/HYD/2024[2018-19]Status: DisposedITAT Hyderabad07 Jan 2025AY 2018-19

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Manjunatha, G.आ.अपी.सं /Ita Nos.1084 To 1088 & 1027/Hyd/2025 (िनधा"रण वष"/Assessment Years: 2014-15 To 2019-20) M/S Ace Tyres (P) Ltd Vs. Acit Hyderabad Central Circle 1(2) Pan:Aadca2210N Hyderabad (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri M.V.Prasad, Ca राज" व "ारा/Revenue By:: Dr. Sachin Kumar, Sr. Ar सुनवाई की तारीख/Date Of Hearing: 02/09/2025 घोषणा की तारीख/Pronouncement: 24/09/2025 आदेश/Order Per Vijay Pal Raothese Six Appeals By The Assessee Are Directed Against The Six Separate Orders Dated 29/05/2025, 30/05/2025, 04/06/2025, 096/06/2025, 17/06/2025 & 14/07/2025 Of The Learned Cit (A)-11, Hyderabad Arising From The Assessment Order Passed U/S 143(3) R.W.S. 147 Of The Act, Pursuant To The Search & Seizure Operations U/S 132 Of The Act, Dated 04/01/2023 In Case Of Exel Group Of Companies Including The Assessee For The A.Ys 2014-15 To 2019-20 Respectively. Since Common Issues Are Raised In These Group Of Six Appeals Arising From Same Facts & Search & Seizure Operation, Therefore, For The Sake Of Convenience, All Page 1 Of 78

For Appellant: Shri M.V.Prasad, CAFor Respondent: : Dr. Sachin Kumar, Sr. AR
Section 132Section 143(3)Section 148Section 148BSection 149Section 149(1)(b)Section 151

Munirathnam Chetty and P Satyanarayana Chetty vs, Income Tax Officer (Supra) held as under: “Having gone through the reasons given by the Income-tax Officer for starting the proceedings under section 147, I am unable to agree with the contention of the petitioner that reasons have not been recorded ... found that they bear no resemblance to the facts of the present case. In that case, the Supreme Court observed, the Income-tax Officer does not set out any reason for coming to the conclusion that this is a fit case to issue notice under section 148. He vaguely referred

Vijay Sadwal, Faridabad Haryana vs. ITO, Ward-2(5), Faridabad

In the result, appeal of Revenue in ITA No

ITA 3554/DEL/2023[2017-18]Status: DisposedITAT Delhi07 Jan 2025AY 2017-18

Bench: Ms. Madhumita Roy & Shri Naveen Chandrathe Income-Tax Officer Vs. Shri Paras Jain Ward – 58(7) 164-B, Gali No. - 5 Delhi Azad Nagar, East Delhi

For Appellant: Shri Ajit Gandhi, CAFor Respondent: Ms. Harpreet Kaur Hansra Sr. DR
Section 147Section 148Section 148ASection 151ASection 69Section 69C

3554/DEL/2024 (A.Y. 2018-19) The Income-tax Officer Vs Shri Paras Jain IN THE INCOME TAX APPELLATE TRIBUNAL, DELHI ‘F’ BENCH, NEW DELHI BEFORE Ms. MADHUMITA ROY, JUDICIAL MEMBER, AND SHRI NAVEEN CHANDRA, ACCOUNTANT MEMBER The Income-tax Officer Vs. Shri Paras Jain Ward – 58(7) 164-B, Gali

Iswar Chand Dubey, Delhi vs. ITO, Ward-68 (1), Delhi

ITA 2985/DEL/2023[2017-18]Status: DisposedITAT Delhi07 Jan 2025AY 2017-18

Bench: Shri Satbeer Singh Godara & Shri Brajesh Kumar Singh

Section 147Section 151Section 2(22)(e)

facts made in the notice was erroneous. The assessee may also prove that no new facts came to the knowledge of the Income-tax Officer after completion of the assessment proceeding. We are not expressing any opinion on the merits of the case. The questions of fact

Punit Kumar Aggarwal, Delhi vs. ITO, Ward-36(2), Delhi

ITA 2983/DEL/2023[2017-18]Status: DisposedITAT Delhi07 Jan 2025AY 2017-18

Bench: Shri Satbeer Singh Godara & Shri Brajesh Kumar Singh

Section 147Section 151Section 2(22)(e)

facts made in the notice was erroneous. The assessee may also prove that no new facts came to the knowledge of the Income-tax Officer after completion of the assessment proceeding. We are not expressing any opinion on the merits of the case. The questions of fact

Tejash Ramesh Shah, HUF, Mumbai vs. ITO 25 (3) - 1, Mumbai

In the result, the appeals of the assessee bearing ITA Nos

ITA 5813/MUM/2024[2015-16]Status: DisposedITAT Mumbai06 Jan 2025AY 2015-16

Bench: Shri Anikesh Banerjee & Miss Padmavathy S.

For Appellant: Shri Mehul ShahFor Respondent: Shri Hemanshu Joshi (SRDR)
Section 10(38)Section 143(3)Section 147Section 250Section 68

short, ‘the Act’) for Assessment years 2015-16 and 2014-15, date of orders04/10/2024.Impugned orders were emanated from the order of theLd. Income-tax Officer-25(3)(5), order passed under section 143(3) read with section 147 of the Act,1961 for A.Y. 2014-15 and order passed under

Pallavi Pal, Noida vs. Ward 5(2)(1), Noida, Aayakar Bhawan, Gautam Budh Nagar

Accordingly, Revenue’s appeal in this case is dismissed

ITA 4657/DEL/2024[2012-13]Status: DisposedITAT Delhi06 Jan 2025AY 2012-13

Bench: Shri Anubhav Sharma & Shri Krinwant Sahayita No.4657/Del/2019 (Assessment Year 2008-09) Income Tax Officer, Shri Vijay Shankar Ward-66(4), Bajpai, New Delhi. Vs. 104, Riico Ind. Area, School Of Aeronautics Delhi Jaipur Highway, Neemrana, Rajsthan-301705. Pan-Aeppb6550D (Appellant) (Respondent) Assessee By Shri Rahul Bardia, Ca Department By Ms. Harpreet Kaur, Sr. Dr Date Of Hearing 19/08/2025 Date Of Pronouncement 25/08/2025

Section 147Section 148Section 253(2)Section 271Section 271(1)(c)

under: "148. Issue of notice where income has escaped assessment - (1) Before making the assessment, reassessment or precomputation under Section 147, the Income-tax Officer shall serve on the Assessee a notice containing all or any of the requirements which may be included in a notice under sub-section

Rajesh Kumar, Delhi vs. ITO, Ward-31(3), Delhi

ITA 4642/DEL/2024[2010-11]Status: DisposedITAT Delhi06 Jan 2025AY 2010-11

Bench: Shri Satbeer Singh Godara

Section 144Section 147Section 148

DELHI BEFORE SHRI SATBEER SINGH GODARA, JUDICIAL MEMBER ITA Nos. 4641 & 4642/Del/2025 Assessment Yrs: 2015-16 & 2016-17 Purys Enterprises Private Limited, Vs Income-tax Officer, 10G/F MCD Park Marg, Hemkunt 20(1), New Delhi. Colony, Greater Kailash, South Delhi- 110048. PAN: AAATD 2458 H APPELLANT RESPONDENT Assessee represented

Horizon Dwellings Private Limited, Bareilly vs. PCIT, Bareilly

In the result, the appeal of the assessee is allowed for statistical purposes

ITA 77/LKW/2022[2017-2018]Status: DisposedITAT Lucknow06 Jan 2025AY 2017-2018

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguriahorizon Dwellings Pvt Ltd V. Pcit, Bareilly, Navjeevan Appartments, Income Tax Department, Opposite Parag Factory, Bareilly (Up)-243001. Badaun Road, Kargaina, Bareilly-243001. Pan:Aacch6839F (Appellant) (Respondent) Appellant By: Shri Rakesh Garg, Adv. Respondent By: Shri Sunil Kumar Rajwanshi, Addl. Cit(Dr) O R D E R

For Appellant: Shri Rakesh Garg, AdvFor Respondent: Shri Sunil Kumar Rajwanshi, Addl
Section 143(3)Section 263

omitted. CIT v. Goyal Private Family Specific Trust, (171 ITR 698) (AIL) “6. There is no finding by the Commissioner that the Income-tax Officer reached an erroneous conclusion and that, on the facts and circumstances of the case, the conclusion would have been different. The orders of the Income ... prejudicial to the interest of the Revenue. It was for the Commissioner to point out as to what error was committed by the Income-tax Officer in having reached the conclusion that the income of the trust was exempt in its hands and was assessable only in the hands

Mintu Das, Kolkata vs. ACIT, Cir. 28, Kolkata

In the result, appeal of the assessee is allowed as per terms indicated above

ITA 8/KOL/2024[2015-16]Status: DisposedITAT Kolkata06 Jan 2025AY 2015-16

Bench: Shri Rajesh Kumar & Shri Sonjoy Sarmai.T.A. No.08/Kol/2024 Assessment Year: 2015-16 Mintu Das………………………...………........………………....Appellant C/O S. N. Ghosh & Associates, Advocates, 2, Garstin Place, 2Nd Floor, Suite No.203, Kolkata –1. [Pan: Adppd3034M] Vs. Acit, Circle-28, Kolkata…….……….…............................…..…..... Respondent Appearances By: Shri Somnath Ghosh, Advocate, Appeared On Behalf Of The Appellant. Shri Pradip Biswas, Addl. Cit- Sr. Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : October 21, 2024 Date Of Pronouncing The Order : January 06, 2025 आदेश / Order Per Sonjoy Sarma: The Present Appeal Has Been Preferred By The Assessee Against The Order Dated 13.11.2023 Of The National Faceless Appeal Centre [Hereinafter Referred To As ‘Cit(A)’] Passed U/S 250 Of The Income Tax Act (Hereinafter Referred To As The ‘Act’) Pertaining To Assessment Year 2015-16. 2. In This Appeal, The Assessee Challenged The Validity Of The Assessment Proceedings Completed U/S 143(3) Of The Act & Consequent To That, An Addition Of Rs.69,42,916/- U/S 68 R.W.S. 115Bbe Of The Act & Further Addition Of A Sum Of Rs.4,86,004/- U/S 69 R.W.S. 115Bbe Of The Act. 3. Brief Facts Of The Case Are That The Assessee Filed His Return Of Income On 28.09.2015 By Declaring A Total Income Of Rs.16,50,920/-. The Case Of The Assessee Was Selected For Scrutiny Under Compulsory

Section 10(38)Section 115BSection 143(2)Section 143(3)Section 250Section 68Section 69

income of the assessee being less than Rs.20 Lakhs, the jurisdiction for assessing the income of the assessee vested with the Income-tax Officer. However, the assessment order in the case of assessee has been framed by the ACIT, Circle-38, Midnapore. In absence of any specific order ... case, prima facie it indicates that the assessment in the case of the assessee ought to have been framed by the Income-tax Officer and not by the ACIT as the income declared in the Income-tax return is less than Rs.20 Lakhs. Now, whether under such given facts

Power Links Transmission Ltd., New Delhi vs. Addl. CIT, Special Range- 7, New Delhi

In the result, the appeal of the assessee is allowed

ITA 4599/DEL/2019[2012-13]Status: DisposedITAT Delhi03 Jan 2025AY 2012-13

Bench: Shri S. Rifaur Rahman & Shri Sudhir Kumarassessment Year: 2012-13 Powerlinks, Transmission Ltd. Vs Additional 10Th Floor, Dlf Tower-A, Commissioner Of District Centre, Jasola, Income Tax, Spl. Range New Delhi. 7 New Delhi Pan No. Aabct7775M (Appellant) (Respondent)

Section 143(2)Section 143(3)Section 147Section 271(1)(c)Section 274Section 3ASection 80I

rectification of mistakes as contained in section 154 of the Income-tax Act, 1961. The power of rectification of mistakes conferred upon the Income-tax Officer is circumscribed by the provisions of section 154 of the Act. The said power can be exercised when the mistake is apparent. Even ... well-settled principle of law that what cannot be done directly cannot be done indirectly. If the Income-tax Officer does not possess the power of review, he cannot be permitted to achieve the said object by taking recourse to initiating a proceeding of reassessment. In a case of this