Naval Seth vs ACIT Circle -28(1)
Case No: ITA No. 6210/DEL/2025
Court: INCOME TAX APPELLATE TRIBUNAL, DELHI BENCH ‘A’, NEW DELHI
Date: 1/6/2026
Parties Involved
appellantShri Naval Seth
respondentACIT Circle-28(1)
Facts Summary
The assessee, Late Shri Ghansham Dass Seth, did not file a return for A.Y. 2016-17. An order u/s 148A(d) was passed on 31.07.2022 due to various cash deposits and withdrawals in the assessee’s joint account, and the income arising from these transactions was not offered for taxation. A subsequent notice u/s 148 was also issued on 31.07.2022. The assessment was finalized in the name of the legal heir, Shri Naval Seth, u/s 147 r.w.s. 144, vide order dated 31.05.2023 at an assessed income of Rs. 12…
Decision in favour of
Assessee
Legal Issues
- 1. Lack of valid approval u/s 151(ii) of the Act for the issuance of order u/s 148A(d) and notice u/s 148.
Precedents Relied Upon
3 precedents cited in this judgement.