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INCOME TAX APPELLATE TRIBUNAL (CHANDIGARH BENCH)
VIKRAM SINGH YADAV, ACM, PARESH M. JOSHI, JM
Income Tax Department – Appellant
Versus
Firm – Respondent
| Table of Content |
|---|
| 1. factual matrix regarding initial return and compliance failures. (Para 2 , 3 , 4 , 5) |
| 2. burden of proof on the assessee and failure to produce required details. (Para 6 , 11 , 12 , 16) |
| 3. procedural non-compliance and its implications. (Para 13 , 14 , 15) |
| 4. dispute over the appellate authority's decisions. (Para 20 , 21 , 22) |
| 5. court's directive for due diligence and clarity in assessment. (Para 24 , 25 , 26) |
आदशे/ORDER
PER PARESH M. JOSHI, JM
This is an appeal filed by the revenue under Section 253 of the Income Tax Act, 1961 before this Tribunal as and by way of second appeal under the Income Tax Act, 1961 . The relevant Assessment Year is AY 2018-19. The corresponding previous year period is from 01.04.2017 to 31.03.2018. The Revenue is aggrieved by order bearing No. ITBA/NFAC/S/250/2023-24/1058998764(1) dated 22.12.2023 which is hereinafter referred to as the “Impugned order” passed in the first appeal under Section 250 of the Income Tax Act, 1961 .
Factual Matrix
2. The assessee is a Firm. The assessee filed the original return of the Income [RoI] on 24.07.2018 for ASSESSMENT YEAR 2018-19 and had declared total income NIL.
3. The return of Income was processed u/
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