Smt. Snigdha Jain Vs ACIT (Central)-2 (ITAT Indore)
The case before the Income Tax Appellate Tribunal Indore involved four appeals filed against a consolidated order of the Commissioner of Income-tax (Appeals)-3, Bhopal, arising from a consolidated assessment order passed under Sections 153A read with 143(3) for Assessment Years (AYs) 2010–11, 2011–12 and 2012–13, and under Section 143(3) for AY 2014–15. The assessments were initiated following a search conducted on 28.02.2014 in the Doshi Group, which included the assessee. The assessee, engaged in money lending and partnership activities, filed returns in response to notices issued under Section 153A for preceding years and separately for AY 2014–15.
Out of seven years covered in assessment, the Assessing Officer accepted returned income for three years without variation, while additions were made in four years (AYs 2010–11 to 2012–13 and 2014–15). Appeals filed before the Commissioner (Appeals) for these four years were dismissed through a consolidated ex-parte order due to non-prosecution, despite multiple opportunities granted over several years.
For AYs 2010–11, 2011–12, and 2012–13, the assessee submitted that non-appearance before the appellate authority was due to multiple factors, including lack of familiarity with tax procedures, the impact of the COVID-19 pandemic, and disruptions during the relevant period. It was also argued that the additions arose mainly from an initial surrender and that related matters concerning the assessee’s father-in-law were being remanded for fresh adjudication. The Department did not oppose the request for remand.
