Reassessment Vitiated by Cross-Examination Denial & Section 147 Use Instead of 153C: ITAT Surat

Advertisement PVR Engineering Co. Vs ITO (ITAT Surat) The assessee appealed against the order of the Commissioner of Income Tax (Appeals) confirming an assessment framed under Section 143(3) read with Section 147 of the Income-tax Act, 1961 for AY 2011-12. The Tribunal first condoned a delay of 128 days in filing the appeal after accepting the assessee’s explanation that the appellate order, served electronically, had not come to his notice due to limited knowledge of online proceedings and that the appeal was filed immediately after discovering the order. The reassessment had been initia...