2025 (5) TMI 2319

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....ana ORDER PER RENU JAUHRI [A.M.] :- This appeal is filed by the assessee against the order of the Learned Commissioner of Income-tax (Appeals), Mumbai/National Faceless Appeal Centre, Delhi [hereinafter referred to as "CIT(A)"] dated 07.01.2025 passed u/s. 250 of the Income-tax Act, 1961 [hereinafter referred to as "Act"] for Assessment Year [A.Y.] 2017-18. 2. The assessee has raised t....

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....notice which is in violation of CBDT circular no. 19 of 2019 dated 14.08.2019 Appeal 5. On the facts and circumstances of the case and law, the Ld. CIT(A) erred in confirming addition of Rs. 47,61,500/- u/s 69C of Income Tax Act, 1961 without considering the fact that source for purchase of property is from explained source 6. On the facts and circumstances of the case and law, t....

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....g." 3. We have heard the rival submissions. At the outset, it has been mentioned by Ld. AR that since the amount involved in this case is less than Rs. 50,00,000/- and more than three years period has elapsed after AY 2017-18, therefore, the notice u/s 148 could not have been issued on 20.07.2022 i.e. beyond three years as per the provisions of the Act. Ld.AR has placed reliance on the decision....

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.... 3year period on 30/06/2021 then for validating the said notice the second condition must be satisfy in respect of the monitory limit regarding the income that escaped assessment. In the present facts of the case it is noted that the income that was said to have escaped assessment as per reasons recorded was Rs. 26,46,000/-. Thus the notice issued beyond period of 3 years under the new law in the ....