Back
INCOME TAX APPELLATE TRIBUNAL (AHMEDABAD BENCH)
Dr. B.R.R. Kumar, VP, Ms. Suchitra Kamble, J
Shri Navin N. Patel – Appellant
Versus
Commissioner of Income-tax (Appeals), National Faceless Appeal Centre [NFAC], Delhi – Respondent
| Table of Content |
|---|
| 1. grounds of appeal and factual background. (Para 1 , 2 , 3 , 4) |
| 2. arguments regarding reopening of assessment. (Para 5 , 6 , 7) |
| 3. analysis of reopening validity and evidence. (Para 8 , 9 , 10) |
| 4. legal standards for reopening assessments. (Para 11 , 12) |
| 5. conclusion quashing the reassessment. (Para 13 , 14 , 15) |
ORDER
This appeal has been filed by the Assessee against the order of the learned Commissioner of Income-tax (Appeals), National Faceless Appeal Centre [NFAC], Delhi (in short ‘the CIT(A)’) dated 01.09.2023 passed under Section 250 of the Income-tax Act, 1961 [hereinafter referred to as "the Act" for short], for Assessment Year (AY) 2012-13.
“1. That the Hon'ble CIT(A) has erred in law and on the facts of the case in confirming the action of ld. AO in reopening the assessment by invoking the provisions of section 147 of the Income Tax Act, 1961 ("the Act") and completing the assessment, commenced under invalid exercise of powers u/s 147 of the Act. Under the facts and circumstances of the case, the action of reopening is without jurisdiction and not permissible either in law or on fact. The present proceedings, therefore, are required to be quashed being bad i
An indispensable Tool for Legal Professionals, Endorsed by Various High Court and Judicial Officers
Please visit our Training & Support
Center or Contact Us for assistance
Scan Me!
India’s Legal research and Law Firm App, Download now!
For Daily Legal Updates, Join us on :
Back to top
