INCOME TAX APPELLATE TRIBUNAL (AHMEDABAD BENCH)
BRR Kumar, Vice President, T. R. Senthil Kumar, Judicial Member
Mahaveer Singh – Appellant
Versus
PCIT – Respondent
| Table of Content |
|---|
| 1. reassessment triggered by unreported cash transactions. (Para 1 , 2) |
| 2. pcit invokes section 263 for missed penalty u/s 270a. (Para 3) |
| 3. assessee argues penalty independent of assessment. (Para 4 , 5 , 6) |
| 4. belated return triggers under-reporting penalty u/s 270a(2)(b). (Para 7 , 8) |
| 5. courts differ; allahabad hc supports revision for penalty omission. (Para 9) |
| 6. revision order upheld; appeal dismissed. (Para 10 , 11) |
आदेश/ORDER
PER: T.R. SENTHIL KUMAR, JUDICIAL MEMBER
This appeal is filed by the Assessee as against Revision order dated 25-03-2025 passed by the Principal Commissioner of Income Tax, Ahmedabad-1, arising out of the assessment order passed under section 143(3) r.w.s. 147 of the (hereinafter referred to as ‘the Act’) relating to the Assessment Year 2018-19.
2. Brief facts of the case is that the assessee is an individual has not filed the Return of Income for the Asst. Year 2018-19. Information received from the insight portal of the Department that the assessee made cash deposit of Rs.1,26,85,410/- and withdrawal of Rs.7,45,118/- in his ICICI Bank account, Ahmedabad-Relief Road Branch during the Financial Year 2017-18 but not filed the Return of Income.
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