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INCOME TAX APPELLATE TRIBUNAL (HYDERABAD BENCH)
SHRI RAVISH SOOD, JM, SHRI MADHUSUDAN SAWDIA, AM
Income Tax Officer – Appellant
Versus
Venkata Ramanamma – Respondent
| Table of Content |
|---|
| 1. assessment initiated due to significant financial transactions. (Para 1 , 2 , 3) |
| 2. arguments on procedural lapses in notice issuance. (Para 4 , 5) |
| 3. consequences of failing to obtain valid authority sanction. (Para 11 , 16) |
| 4. importance of proper authority for notice approval. (Para 12 , 13) |
| 5. final ruling dismissing the appeal due to invalid proceedings. (Para 18) |
ORDER
PER RAVISH SOOD, JM:
The present appeal filed by the revenue is directed against the order passed by the Commissioner of Income Tax (Appeals), National Faceless Appeal Centre, Delhi, dated 31/12/2024, which in turn arises from the order passed by the Assessing Officer (for short, “AO”) under section 147 r.w.s 144 r.w.s 144B of the Income Tax Act, 1961 (for short, “the Act”), dated 19/02/2024 for the Assessment Year 2018–19. The revenue has assailed the impugned order on the following grounds of appeal before us:
(i) Whether the Ld. CIT(A) is correct in allowing the assessee's appeal on 31.12.2024 relying on the order dated 01.10.2024 of the Hon'ble ITAT, Mumbai, which in turn relied on the judgement of Hon'ble Bombay High Court in Siemens Financial Services (P.) Ltd. v/s DCIT, (2023) 457 ITR 647 (B
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