PANKAJ KUMAR GUPTA,AZAMGARH vs. INCOME TAX OFFICER, INCOME TAX OFFICER
In the result, both the appeals of the assessee stand allowed for statistical purposes
ITA 125/VNS/2023[2012-13]Status: DisposedITAT Varanasi10 Oct 2025AY 2012-13
Bench: Shri. Sudhanshu Srivastava
For Appellant: S/Shri Piyush Kumar Kamal and Abhishek Kumar Gupta, AdvocatesFor Respondent: Smt Amandeep Kaur, D.R
Section 144Section 147Section 148Section 151Section 271(1)(c)
u/s 148 of the Act could have been validly issued after the expiry of 6 years from the end of the relevant assessment year as per the old provisions of section 147 to section 151 existing on the statute books upto
31.3.2021 and penalty proceeding on such basis proceeded to arrive at conclusions on factually incorrect basis and, total misconception
