Case Law Details
Sanjay Punamchand Kothari Vs ACIT (ITAT Pune)
Sanjay Punamchand Kothari Vs. ACIT (ITAT Pune): Admissions in Search or Survey Cases and the Invalidity of Assessment Orders Lacking DIN
In the realm of income tax assessments, the case of Sanjay Punamchand Kothari vs. ACIT (Income Tax Appellate Tribunal, Pune) sheds light on two crucial aspects. Firstly, it highlights the significance of admissions made by the searched party during a search or survey operation. Secondly, it underscores the consequences of an assessment order that lacks the Document Identification Number (DIN) and Order number, rendering it invalid. This article provides a detailed analysis of this case, examining the arguments, decisions, and implications.
Background of the Case
Sanjay Punamchand Kothari, the assessee, was the subject of scrutiny for two assessment years: 2017-18 and 2018-19. The former assessment year involved twin appeals, IT(SS)A Nos. 12/PUN/2021 and 11/PUN/2022, arising from the orders of the Commissioner of Income Tax (Appeals) [CIT(A)], Pune-11, dated 10.11.2021 and 25.01.2022. These orders pertained to proceedings under Section 154 and Section 143(3) read with Section 153A of the Income Tax Act, 1961 (referred to as “the Act”).
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