JAI PRAKASH SINGH,PATNA vs. ITO, WARD- 6 (1), PATNA
In the result, appeal of the assessee stands partly allowed for
ITA 297/PAT/2025[2015-16]Status: DisposedITAT Patna30 Sept 2025AY 2015-16
Bench: Shri Duvvuru Rl Reddy(Kz) Assessment Year : 2015-16 Jai Prakash Singh, Near Shiv Vs. Ito, Ward 6(1), Patna Mandir, Khajpura, Patna- 800014, Bihar Pan/Gir No. Ainps 1974 Q (Appellant) .. ( Respondent) Assessee By : None Revenue By : Shri Ashwani Kumar Singhal, Jcit Date Of Hearing : 28/08/2025 Date Of Pronouncement : 30/09/2025 O R D E R The Present Appeal Is Directed At The Instance Of Assessee Against The Order Of Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nafc), New Delhi Nfac), Delhi Dated 21.08.2024 In Appeal No.Cit(A), Patna -1/11368/2019-20 Passed For Assessment Year 2015-16. 2. The Appeal Is Time Barred By 239 Days. The Assessee Has Filed Condonation Petition Stating That The Assessee Being A Senior Citizen & Was Not Conversant With The Computer System. The Notices Were Issued To The Assessee By The Ld Cit(A) In The Income Tax Portal & Since The Assessee Was Not Aware Of The Notices, No Submissions As Well As Paper Book Was Filed.
For Appellant: NoneFor Respondent: Shri Ashwani Kumar Singhal, JCIT
Section 133(6)Section 144Section 147Section 148Section 2(47)Section 53A
reassessment u/s.147
of the Act and notice u/s.148 was issued to the assessee. In response to notice, the assessee filed return of income. The Assessing Officer opined that since the assessee had relinquished ownership right over his share by entering into development agreement, as such, the provision of section 53A of T.P. Act attracted the capital gain arising
