Case Law Details
Paramjit Singh Vs PCIT (ITAT Delhi)
Introduction: The case of Paramjit Singh Vs PCIT (ITAT Delhi) revolves around an appeal filed by the assessee against the order of the ld. PCIT, Rohtak, dated 17th February 2022, framed under section 263 of the Income-tax Act, 1961, pertaining to the Assessment Year 2012-13.
Detailed Analysis: The grievances presented by the assessee highlight concerns regarding the jurisdiction assumed by the Principal Commissioner of Income Tax (PCIT) under section 263. The appellant contests the decision, arguing errors in law, incorrect factual findings, and a violation of principles of natural justice.
The crux of the matter lies in the reassessment order dated 6th August 2019, framed under section 147 r.w.s 143(3) of the Act, which the PCIT deemed both erroneous and prejudicial to the interests of revenue. However, upon thorough scrutiny, it was found that the Assessing Officer had duly considered the source of cash deposits and examined relevant documents, including the sale transaction of land.
While the PCIT issued a show cause notice citing discrepancies, the Tribunal observed that specific queries were addressed, and replies were duly filed by the assessee. Furthermore, it was noted that no addition was made by the Assessing Officer based on the reasons for reopening the assessment.
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