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INCOME TAX APPELLATE TRIBUNAL (AGRA BENCH)
M Balaganesh, Accountant Member, Sunil Kumar Singh, Judicial Member
Agra Shine Footwear – Appellant
Versus
ITO, Ward-2(1)(1), Agra – Respondent
| Table of Content |
|---|
| 1. procedural background and grounds for challenging the assessment of a dissolved entity. (Para 1 , 2 , 3 , 4 , 5) |
| 2. evaluation of evidence regarding the dissolution of the partnership firm. (Para 6 , 7 , 8 , 9 , 10 , 11) |
| 3. applying the legal principle that jurisdictional notices cannot be served on non-existent entities. (Para 12 , 13 , 14) |
| 4. final outcome regarding quantum assessment and penalty. (Para 15 , 16) |
ORDER
PER: SUNIL KUMAR SINGH, J.M.
The facts and issues involved in both these appeals are almost identical, hence, for the sake of convenience and brevity, these appeals are being decided by this common order. The facts of ITA No. 260/Agr/2026 are only being narrated hereunder:-
ITA No. 260/Agr/2026
2. This appeal is directed against the impugned order dated 13.01.2026 passed in appeal No NFAC/2016-17/10386788 by the ld. Commissioner of Income Tax (NFAC), Delhi (hereinafter referred to as the “CIT(A) u/s. 250 of the Income Tax Act, 1961 (hereinafter referred to as the “Act”) for the A.Y. 2017-18, wherein ld CIT(A) has dismissed assessee’s first appeal.
3. The brief facts state that the assessee as partnership firm (according to the assessing officer) did
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