Jagatjeet Singh vs ACIT

Parties Involved

Facts Summary

The assessee, Jagatjeet Singh, filed an original return declaring an income of Rs. 46,63,630/- on 23.07.2022. The case was selected for compulsory scrutiny after a survey under section 133A was conducted on 01.09.2022 in the case of Baby Joy Group, and a consequential survey was conducted at the business premises of the assessee. The assessment was completed under section 143(3) of the Act via order dated 31.03.2024 at the returned income. Subsequently, the Principal Commissioner of Income Tax (Central) noted that the assessment had been completed without requisite verification of a cash payment made for the purchase of property by the assessee, which was noticed during the survey proceedings. Relevant documents were extracted from the assessee's iPhone and were part of the impounded incriminating material. A show-cause notice under section 263 of the Act was issued on 14.11.2024, and after considering the assessee’s reply, an order under section 263 was passed on 17.03.2025, setting aside the order under section 143(3) dated 31.03.2024. Aggrieved, the assessee preferred an appeal before the Tribunal.…

Legal Issues

• 1. Whether the Principal Commissioner of Income Tax (Central) erred in invoking the provisions of section 263 of the Income Tax Act and setting aside the assessment order passed by the Assessing Officer under section 143(3).
• 2. Whether the property purchased in the name of the assessee’s wife should result in an addition in the hands of the assessee.
• 3. Whether WhatsApp chats can be treated as valid evidence.

Judgment Outcome

Decided in favour of Revenue.

Precedents Relied Upon

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