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INCOME TAX APPELLATE TRIBUNAL (CHANDIGARH BENCH)
SMT.ANNAPURNA GUPTA, ACM, SHRI R.L. NEGI, J
PARVEEN KUMAR MITTAL YAMUNA NAGAR – Appellant
Versus
PR.CIT PANCHKULA – Respondent
| Table of Content |
|---|
| 1. claim of nullity of reassessment order. (Para 1 , 2 , 3) |
| 2. challenge to the validity of assessment order in collateral proceedings. (Para 4 , 5 , 6 , 10) |
| 3. jurisdiction needs valid grounds and information. (Para 12 , 14 , 15) |
| 4. assessment for reopening requires clear justification. (Para 18 , 22) |
| 5. final ruling last stages of appeal. (Para 24) |
आदेश/Order
Per Annapurna Gupta, Accountant Member:
The above appeal has been preferred by the assessee against the order of the Principal Commissioner of Income Tax, Panchkula (in short the ‘Ld.Pr.CIT) dated 19.03.2021 relating to assessment year 2011-12, passed u/s 263 of the Income Tax Act, 1961 (hereinafter referred to as ‘Act’ in exercise of revisionary jurisdiction.
2. As transpires from the order of the Ld. Pr.CIT the revisionary jurisdiction u/s 263 of the Act was exercised by him on an order passed by the Assessing Officer (AO) in re- assessment proceedings u/s 147 of the Act, for the reason that he found that the order had been passed in undue haste without conducting necessary inquiries. The Ld.Pr.CIT found that the AO had failed to make independent inquiries to verify the source of cash deposited in bank by the ass
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