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INCOME TAX APPELLATE TRIBUNAL (AGRA BENCH)
Sunil Kumar Singh, Judicial Member, M Balaganesh, Accountant Member
Gaurav Rathore – Appellant
Versus
ITO – Respondent
| Table of Content |
|---|
| 1. background of appeals from search operation (Para 1 , 2 , 3 , 4) |
| 2. assessee challenges s.147 jurisdiction post-search (Para 5) |
| 3. s.153c mandatory for third persons; s.147 invalid (Para 6) |
| 4. reassessments quashed; appeals allowed (Para 7) |
ORDER
PER M BALAGANESH, A.M.
1. This is an appeal of the assessee arising out of the order of Ld. Commissioner of Income Tax (Appeals) [hereinafter referred to as ld.CIT(A)] in Appeal Nos. NFAC/2017-18/10217251, NFAC/2019-20/10467224, NFAC/2017- 18/10244539, dt 28.11.2025, 23.12.2025, 10.11.2025 of the A.Y. 2018-19, & 2020-21 against the order passed by National Faceless Assessment Centre/Unit (hereinafter referred to as the ld. A.O) u/s. 250 of the Income Tax Act, 1961 (hereinafter referred to as the “Act”).
2. All these appeals have identical issue and emanating out of the same search operation. Hence, they are taken up together and disposed of by this common order for the sake of convenience.
3. The identical issue raised by the assessee in all these appeals is challenging the validity of assumption of jurisdiction u/s. 147 of the Act and consequently framing of assessment by the ld A.O. u/s. 147 of the Act for various assessment o
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