Sajja Kiran Kumar vs. The Income Tax Officer

Parties Involved

Facts Summary

The assessee, Sajja Kiran Kumar, had made substantial cash deposits in his bank account but did not file his income return for the assessment year 2018-19. The Assessing Officer (AO) initiated reassessment proceedings under section 147 of the Income-tax Act, 1961. The AO issued a notice under section 148A(b) on 21/03/2022, which the assessee failed to respond to. Consequently, the AO passed an order under section 148A(d) on 07/04/2022. The assessee filed his return on 16/09/2022. The AO observed that the assessee's total bank credits exceeded his declared business turnover and made an addition under section 69A of the Act. The assessee appealed against the order passed by the Commissioner of Income Tax (Appeals) and the subsequent order by the Income Tax Appellate Tribunal.…

Legal Issues

• 1. Whether the Assessing Officer had valid jurisdiction to issue the notice under section 148 of the Act without obtaining approval from the specified authority under section 151 of the Act.

Judgment Outcome

Decided in favour of Assessee.

Precedents Relied Upon

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