Case Law Details
Rajkumar Anandchand Jain Vs DCIT (ITAT Mumbai)
In a significant ruling that underscores the importance of adherence to procedural fairness in tax appeals, the Mumbai Bench of the Income Tax Appellate Tribunal (ITAT) has delivered a noteworthy judgment in the case of Rajkumar Anandchand Jain Vs Deputy Commissioner of Income Tax (DCIT). The crux of the matter revolves around the Commissioner of Income Tax Appeals (CIT(A)) upholding the Assessing Officer’s (AO) decision without duly considering the merits of the case, which has been identified as a violation of Section 250(6) of the Income Tax Act, 1961. This case highlights the procedural safeguards designed to ensure fair adjudication in tax disputes.
The appellant, Mr. Rajkumar Anandchand Jain, contested the appellate order passed by the National Faceless Appeal Centre, Delhi, for the assessment year 2018-19. The CIT(A) had dismissed the appeal against the assessment order under sections 143(3) read with 144B, where an addition of Rs. 14,098,500 was made to the appellant’s income under section 56(2)(x)(b) of the Act. The primary contention was the failure to consider the merits of the case, constituting non-compliance with Section 250(6) of the Act.
The facts of the case reveal that the dispute centered around the purchase of immovable property, where the purchase value was significantly less than the stamp duty value determined by the authority. The AO had added the difference amount to the appellant’s income as per the provisions of section 56(2)(x)(b), which the CIT(A) upheld without considering the appellant’s arguments regarding the date of acquisition and the stamp duty value applicable.
Upon appeal, the ITAT scrutinized the procedural aspects and the merits of the appellant’s arguments. The Tribunal observed that the CIT(A) had failed to address the specific grounds of appeal raised by the appellant, particularly concerning the addition under section 56(2)(x)(b) and the determination of the property’s acquisition date. This oversight was deemed a lapse in following the mandate of Section 250(6), which necessitates a detailed order addressing the appellant’s grounds.
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