https://www.taxtmi.com/caselaws?id=761235 The ITAT Raipur dismissed the appeal filed by a discretionary trust against an assessment order passed under Section 143(3) of the Income Tax Act. The assessment order was issued against an individual beneficiary for unexplained cash deposits under Section 69A, but the trust filed the appeal instead of the beneficiary. The tribunal held that while the trust is the primary assessee under Section 160(1)(iv), the department can directly assess the beneficiary under Section 166. Since the assessment was made against the beneficiary, only she had the right to appeal. The beneficiary was granted liberty to file a delayed appeal before the CIT(Appeals) with liberal consideration for the delay. en-us Wed, 21 Aug 2024 00:00:00 +0530 Thu, 07 Nov 2024 08:47:58 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=761235 The ITAT Raipur dismissed the appeal filed by a discretionary trust against an assessment order passed under Section 143(3) of the Income Tax Act. The assessment order was issued against an individual beneficiary for unexplained cash deposits under Section 69A, but the trust filed the appeal instead of the beneficiary. The tribunal held that while the trust is the primary assessee under Section 160(1)(iv), the department can directly assess the beneficiary under Section 166. Since the assessment was made against the beneficiary, only she had the right to appeal. The beneficiary was granted liberty to file a delayed appeal before the CIT(Appeals) with liberal consideration for the delay. Case-Laws Income Tax Wed, 21 Aug 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=761235