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Mr. Abdul Munaf Irfanudeen vs. PCIT (Central)

Case No: ITA No.1508/Chny/2024, ITA No.1509/Chny/2024, ITA No.1510/Chny/2024, ITA No.1511/Chny/2024, ITA No.1512/Chny/2024, ITA No.1513/Chny/2024
Court: Income Tax Appellate Tribunal, 'A' Bench, Chennai
Date: 9/18/2024

Parties Involved

appellantMr. Abdul Munaf Irfanudeen
respondentPCIT (Central)

Facts Summary

The assessee, Mr. Abdul Munaf Irfanudeen, was engaged in financing business and was not assessed to tax earlier. A relative of the assessee was intercepted carrying cash of Rs.99.75 Lacs, which was seized as no plausible explanation was provided. The assessee admitted the cash belonged to him and offered it for tax in FY 2020-21. Notices under section 153C were issued for various years, but the assessee did not file income returns. Bank statements revealed credits of Rs.168.72 Lacs in the assessee's accounts, leading the Assessing Officer (AO) to estimate income at 8% of gross receipts, concluding it represented business receipts. The Principal Commissioner of Income Tax (Central) revised the assessment, finding it erroneous and prejudicial to the revenue, directing the AO to re-examine the nature of credits. The assessee appealed this revision.

Decision in favour of

Revenue

Legal Issues

  • 1. Whether the Principal Commissioner of Income Tax (Central) was justified in invoking revisionary jurisdiction under section 263?
  • 2. Whether the assessment order passed by the Assessing Officer was erroneous and prejudicial to the interest of the revenue?

Judgment Outcome

Decided in favour of Revenue.

Precedents Relied Upon

3 precedents cited in this judgement.

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