Case Law Details
Muthu Pitchamuthu Prabu Vs Assistant/Deputy Commissioner of Income Tax (International Taxation) (Madras High Court)
The Madras High Court recently passed a significant judgment in the case of Muthu Pitchamuthu Prabu Vs Assistant/Deputy Commissioner of Income Tax (International Taxation), setting aside an income tax assessment order due to procedural lapses and non-consideration of crucial documents submitted by the petitioner. This case revolves around the assessment order dated 29.03.2024 for the assessment year 2022-23 and addresses critical issues related to natural justice and proper procedural compliance under the Income Tax Act, 1961.
Background and Context: The petitioner, Muthu Pitchamuthu Prabu, filed his return of income for the assessment year 2022-23 on 30.07.2022. Subsequently, a notice dated 31.05.2023 was issued under Section 143(2) of the Income Tax Act, 1961 (the I-T Act). The petitioner responded to this notice on 05.06.2023, and further notices under Section 142(1) of the I-T Act followed, to which the petitioner replied, attaching partial bank statements. Despite these responses, a show cause notice dated 26.03.2024 was issued, questioning the investments made by the petitioner in Zerodha from his ICICI Bank account. In response, the petitioner sent an email on 28.03.2024, attaching several crucial documents, including complete bank statements and Form-16. However, the assessment order was issued without considering these documents.
Petitioner’s Grounds of Challenge:
The petitioner challenged the assessment order on two primary grounds:
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