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INCOME TAX APPELLATE TRIBUNAL (DELHI BENCH)
Anubhav Sharma, Judicial Member, Manish Agarwal, Accountant Member
Balraj Sharma – Appellant
Versus
ITO Ward 1(3) – Respondent
| Table of Content |
|---|
| 1. appeal against cit(a) order confirming additions (Para 1 , 2 , 3) |
| 2. grounds challenging cit(a) procedural errors (Para 4) |
| 3. condonation of 440-day delay granted (Para 5 , 6 , 7) |
| 4. additional legal grounds on jurisdiction admitted (Para 8 , 9 , 10) |
| 5. ito lacked jurisdiction per cbdt instruction (Para 11 , 12 , 13 , 14 , 15) |
| 6. judicial precedents on invalid jurisdiction notices (Para 16 , 17 , 18) |
| 7. section 292bb does not cure jurisdiction defect (Para 19) |
| 8. appeal allowed; assessment quashed (Para 20 , 21) |
ORDER
PER MANISH AGARWAL, AM :
The present appeal is filed by the assessee against the order dated 23.02.2024 by Ld. Commissioner of Income Tax (A), National Faceless Appeal Centre (“NFAC”), Delhi [“ld. CIT(A)”] in Appeal No. CIT (A), Gurgaon- 1/11612/2019-20 passed u/s 250 of the Income Tax Act, 1961 [“the Act”] arising from the assessment order dated 23.12.2019 passed u/s 143(3) of the Act pertaining to Assessment Year 2017-18.
2. Brief facts of the case are that the assessee is an individual and filed his return of income on 05.11.2017 declaring total income at INR 39,58,400/-. The case was selected for scrutiny under CASS and the notice was issued by ITO, Ward-1
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