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INCOME TAX APPELLATE TRIBUNAL (GUWAHATI BENCH)
Sonjoy Sarma, Judicial Member, Rakesh Mishra, Accountant Member
Atul Tamuli – Appellant
Versus
Pr. Commissioner of Income Tax (Central), Guwahati – Respondent
| Table of Content |
|---|
| 1. assessee challenges pcit jurisdiction under section 263. (Para 2 , 5) |
| 2. factual background of search and assessments. (Para 3) |
| 3. typographical error in section citation not fatal. (Para 6 , 7) |
| 4. section 263 valid despite pending cit(a) appeal. (Para 8) |
| 5. revision justified for ignoring late dvo report. (Para 9 , 10) |
| 6. assessment erroneous if prejudicial to revenue. (Para 11) |
| 7. section 263 applicable despite section 153d approval. (Para 12) |
| 8. all assessee appeals dismissed. (Para 14 , 15 , 16) |
ORDER
PER RAKESH MISHRA, ACCOUNTANT MEMBER:
All these appeals filed by the assessee are against the common order of the Pr. Commissioner of Income Tax (Central), Guwahati [hereinafter referred to Ld. 'Pr. CIT'] passed u/s 263 (erroneously mentioned as section 264 in the header of the order) of the Income Tax Act, 1961 (hereinafter referred to as ‘the Act’) for AYs 2014-15 to 2020-21 dated 29.03.2024.
1.1 The Registry has informed that all the appeals are barred by limitation by 550 days. The assessee has filed a petition along with an affidavit seeking condonation of delay and explaining the reasons as mentioned below:
“I, Atul Tamuli, S/o: Late. Mohendra Nath Tamuli aged about 5
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