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IN THE HIGH COURT OF CHHATTISGARH AT BILASPUR
Sanjay K. Agrawal, J
RAJ KUMAR BOTHRA – Appellant
Versus
DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-2(1) – Respondent
| Table of Content |
|---|
| 1. conclusion of appeal resulting in method adjustments permissible. (Para 1 , 18) |
| 2. factual background on the appeal and dismissed claims. (Para 2 , 6) |
| 3. arguments around unjust adjustments by assessing officer. (Para 4 , 5) |
| 4. clear criteria that debatable issues require deeper assessment. (Para 11 , 17) |
Sanjay K. Agrawal, J
1. This appeal preferred under Section 260A of the Income Tax Act, 1961 (for short the "Act of 1961") was admitted for hearing on 19.03.2025 by formulating the following substantial question of law:-
“Whether the CIT (Appeals) and the Income Tax Appellate Tribunal are justified in dismissing the appeals holding that the Assessing Officer has rightly processed the return of the appellant herein under Section 143 (1)(a) of the Act ignoring the fact that in light of conflicting judgments on the issue of due date the Assessing Officer was required to resort to the provisions contained in Section 143 (3) / Section 147 of the Act, by recording a finding which is perverse to the record ?"
2. The aforesaid question of law arises for consideration on the following factual backdrop:-
3. The appellant/assessee filed the return of income for Assessment Year
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