Anil Kapoor Vs ITO (ITAT Delhi)
The appeal before the Income Tax Appellate Tribunal (ITAT), Delhi, arose from an order dated 09.01.2025 passed by the Commissioner of Income Tax (Appeals) under Section 250 of the Income Tax Act, 1961, which in turn stemmed from an assessment order dated 21.03.2023 passed by the Assessing Officer under Section 144 read with Section 147 of the Act for Assessment Year 2015–16.
The case was selected for reassessment under Section 147 on the ground of alleged escapement of income amounting to ₹52,49,376. The reasons recorded for reopening included transactions during Financial Year 2014–15 comprising sale of immovable properties aggregating to ₹51,33,334 and interest income of ₹1,16,042. During the reassessment proceedings, several statutory notices and communications were issued to the assessee, including notices under Section 142(1), letters seeking compliance, show cause notices for best judgment assessment under Section 144, and a final show cause notice proposing additions. Except for a partial response to the final show cause notice dated 06.02.2023, no compliance or supporting documents were furnished by the assessee.
In the absence of effective compliance, the Assessing Officer completed the assessment by making additions of ₹51,33,334 on account of sale of immovable property and ₹1,45,553 as interest income. Aggrieved by the assessment order, the assessee filed an appeal before the CIT(A). However, the appellate authority dismissed the appeal on 09.01.2025 due to non-response to notices issued during appellate proceedings.
