2025 (9) TMI 1027

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.... consequently the reassessment is also void ab initio. 2. Heard both the sides and perused the records. 3. Brief facts of the case are that assessee is an individual and filed his original return of income for the AY 2017-18 declaring total income of Rs. 2,60,450/-. Thereafter, the assessee filed revised return of income declaring taxable income of Rs. 3,12,480/-. As per the financial transactions reported in the ITS, assessee has deposited cash amounting to Rs. 18,29,000/- with Indian Overseas Bank at Gonda, UP, during the FY 2016-17 relevant to AY 2017-18. Therefore, AO issued a notice u/s. 148 on 27.3.2021. The assessee was non compliant to notice u/s. 148 as well as notice u/s. 142(1). AO noted that since the Assessee failed to fi....

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.... have a PAN card registered at one address while being assessed for tax purposes in a different jurisdiction. In the present case, PAN of appellant is attached to ITO, Ward 52 based on residential address of appellant: Z 198 Near Masjid, New Ranjit Nagar, New Delhi. It is noticed that office address of appellant is also located in Delhi which is A 137, Near Satyam Cinema, Ranjeet Nagar, Now Delhi though appellant has provided Gonda address in PAN database. Therefore, notice u/s 148 was issued by AO having jurisdiction over PAN number of Appellant. Hence notice u/s 148 can't be held to be invalid. Hence, Grounds No.2, 3 and 6 of the appellant are dismissed." 4. Against the order of the Ld. CIT(A), assessee is in appeal before the Trib....

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.... and permanent address are same, which was updated in the e-filing portal of income tax department. The assessee has applied PAN at the address viz. House No. 155, Rakabganj, City Post Office, Gonda, District Gonda, Uttar Pradesh-271001. The PAN No. AIOPA0771A has been issued by the Income Tax Department vide letter dated nil placed at page book page no. 38 vide Annexure-11. Further, on perusing the notice u/s. 148 of the Act dated 27.03.2021 which has been issued by the ITO, Ward 52(1), Delhi the address mentioned on it is 115/21, Rakabganj, Kotwali Nagar, District, Gonda, Uttar Pradesh-271001, which is without jurisdiction and based on the notice u/s. 148 of the Act, the reassessment order passed by the AO/NFAC, Delhi is also without juri....