Reassessment under Section 147 where a duly e-verified revised return was ignored and addition for unexplained investment deleted on appeal.

Reassessment proceedings under section 147 challenged the addition for unexplained investment on the ground that a revised return was filed and e-verified but ignored; additionally no notice under section 143(2) was issued before framing assessment. The legal basis relied on verification of the revised return (including affidavit and Aadhaar OTP e-verification) and absence of statutory notice to assume jurisdiction. Because the assessment was framed without considering the duly verified revised return and no 143(2) notice was issued, the addition was deleted and the appeal allowed.

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Issues: Whether the addition of Rs.50,50,000/- made as unexplained investment under section 69 and sustained by the lower authorities is liable to be deleted where the assessee filed a revised return in response to notice under section 148 which was e-verified and no statutory notice under section 143(2) was issued before framing assessment under sections 143(3)/147.

Analysis: The assessment was reopened under section 147 and an assessment order under sections 143(3)/147 was passed without taking into account the revised return filed by the assessee on 30/10/2018. The revised return was produced before the Tribunal and shown to be e-verified by Aadhaar OTP, supported by an affidavit certifying its genuineness. The assessment was framed on the premise that the revised return was not e-verified. Further, no statutory notice under section 143(2) was issued for assuming jurisdiction to frame the assessment. The Tribunal considered the statutory framework governing reassessment, the requirement of valid verification of returns, and the need for statutory notices where applicable, and applied these principles to the facts that the revised return was available, e-verified, and was not considered by the assessing officer before making the addition under section 69.

Conclusion: The Tribunal deleted the addition of Rs.50,50,000/- and allowed the assessee's appeal; the assessment and the order of the Commissioner of Income Tax (Appeals) were set aside in respect of the impugned addition.

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