Neelkamal Realtors Suburban Private Limited vs. DCIT, Central Circle

Parties Involved

Facts Summary

The assessee, Neelkamal Realtors Suburban Private Limited, was subject to a search and seizure operation under Section 132 of the Income Tax Act, 1961. Following this, the Assessing Officer reopened the assessment under Section 147 of the Act. The assessee filed a return showing Nil income. The Assessing Officer completed the assessment under Section 143(3) read with Section 147 of the Act, making disallowances. The assessee challenged the assessment orders, questioning the validity of the reopening of assessment under Section 147 of the Act. The assessee argued that the Assessing Officer exceeded his jurisdiction by making additions not based on the reasons recorded for the reopening of assessment.…

Legal Issues

• 1. Validity of reopening of assessment under Section 147 of the Income Tax Act, 1961.
• 2. Validity of the assessment order for Assessment Year 2021-22.

Judgment Outcome

Decided in favour of Assessee.

Precedents Relied Upon

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