Natarajan Vasudevan Vs. The Income Tax Officer, Non Corporate Ward-3(2), Coimbatore

Parties Involved

Facts Summary

The assessee, Natarajan Vasudevan, did not file the return of income for Assessment Year 2020-21. The Assessing Officer (AO) received information about certain financial transactions of the assessee and issued a notice under section 148A(b) of the Income Tax Act, 1961. The assessee filed the return of income on 15.04.2024 declaring a total income of Rs.1,30,600. The AO completed the assessment under section 147, assessing the income at Rs.1,13,48,150. Aggrieved by this, the assessee filed an appeal before the Commissioner of Income Tax / National Faceless Appeal Centre (NFAC), Delhi (CIT(A)), who passed an order on 25.09.2025. The assessee then filed a further appeal before the Tribunal. The assessee submitted additional evidences before the CIT(A), which were refused to be admitted.…

Legal Issues

• 1. Whether the Impugned Order is unjust, unreasonable and bad in law.
• 2. Whether the First Appellate Authority erred in sustaining the additions without considering the explanations and submissions in proper perspective.
• 3. Whether the First Appellate Authority erred in confirming the order of the Assessing Officer regarding the validity of the notice under section 148.
• 4. Whether the First Appellate Authority erred in confirming the order of the Assessing Officer regarding the issuance of notice under section 148 by JAO instead of FAO.
• 5. Whether the First Appellate Authority erred in rejecting the prayer for admission of Additional Evidence under Rule-46A.
• 6. Whether the First Appellate Authority erred in dismissing the appeal without considering the scope and effect of the proviso to section 251(1)(a).

Judgment Outcome

Decided in favour of Assessee.

Precedents Relied Upon

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