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INCOME TAX APPELLATE TRIBUNAL (MUMBAI BENCH)
Shri Rahul Chaudhary, J, Smt Renu Jauhri, ACJ
Income Tax Officer 23(3)(6) – Appellant
Versus
Rahul Hariprasad Tibrewal – Respondent
| Table of Content |
|---|
| 1. core facts of the assessment and appeal. (Para 1 , 2) |
| 2. arguments over the validity of the reassessment notice. (Para 3 , 4 , 5) |
| 3. legal observations on issued notices and required approvals. (Para 6 , 7 , 8 , 9 , 10) |
| 4. final ruling considering jurisdictional compliance. (Para 11) |
ORDER
Per Rahul Chaudhary, Judicial Member:
1. The present appeal and cross objection pertains to Assessment Year 2017-2018. The Revenue has preferred appeal against the order, dated 27/11/2024, passed by the National Faceless Appeal Centre (NFAC), [hereinafter referred to as the ‘CIT(A)’], under Section 250 of the Income Tax Act, 1961 [hereinafter referred to as ‘the Act’], whereby the Ld. CIT(A) had partly allowed the appeal of the Assessee against the Assessment Order, dated 22/05/2023, passed under Section 147 read with Section 144B of the Act, for the Assessment Year 2017-2018. The Assessee has filed cross objection.
2. The relevant facts in brief are that notice under Section 148 of the Act (old regime) was issued to the Assessee for the Assessment Year 2017-2018 on 21/06/2021 (i.e., before the expiry of 4 years from the end of Assessment Year 2017-2018). Subsequently, in compliance
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