Case Law Details
Santosh Khunteta Vs ITO (ITAT Delhi)
Synopsis of Appeal Submission:
1. Facts of the Case: The present appeal has been preferred by the appellant, in respect of the Reassessment Order for the AY 2010-11, passed u/s 147/143(3), by the learned Assessing Officer, ITO, Ward 29(5), New Delhi, dated 29.12.2017, and partly upheld by the learned CIT (Appeals), National Faceless Appeal Centre, vide the appeal order dated 11.9.2023. The appellant is a well reputed medical practitioner. The appellant is a regular taxpayer assessee and has been regularly filing her return of income since last more than 20 years For the AY 2010-11, the appellant had filed its return of income on 31.07.2010 declaring an income of Rs. 5,46,080/-. The case was reopened u/s 148 of the Income tax Act on 29.3.2017, on the basis of an information received from ITO (I&CI), Jodhpur vide their letter No. ITO (I& CI)/JDH/2016-17/2166 dated 30.3.2017 and received by the AO of the appellant on 30.3.2017 through email. The ld. AO, vide his assessment order dated 29.12.2017, had made several additions amounting in total to Rs. 51,23,000/- u/s 56 of the Income Tax Act. On being aggrieved by the same, the appellant has, therefore, filed present appeal against the reassessment order passed by the AO and as partly upheld by the learned CIT(Appeals) NFAC, Delhi.
2. The appellant has raised 7 grounds of appeal. First four grounds are legal grounds challenging the validity and jurisdiction of the impugned reassessment notice, reassessment proceedings and the subject reassessment order for the AY 2010-11, passed u/s 147/143(3) of the Income Tax Act. The remaining 3 grounds are addressing the (de)merits of the impugned additions.
3. First four grounds of appeal are legal grounds and go to the root and the jurisdiction of the matter, and as such these are being represented first.
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