Seema Puri Vs. ITO

Parties Involved

Facts Summary

The case involves an appeal by the assessee, Seema Puri, against the order of the Ld. Additional Commissioner of Income Tax (Appeals), Bhubaneshwar, for the Assessment Year 2011-12. The assessee filed an appeal on several grounds, primarily challenging the reopening of the assessment and the consequent reassessment order. The assessee argued that the notice issued under section 148 of the Income Tax Act, 1961, and the reassessment order under section 147/143(3) were illegal and without jurisdiction. The assessee claimed that she had filed her return of income within the due date, which was acknowledged by the Assessing Officer, making the premise for reopening the assessment factually incorrect.…

Legal Issues

• 1. Validity of the notice issued under section 148 of the Income Tax Act, 1961, and the consequent reassessment order.
• 2. Whether the approval under section 151 of the Act was valid.
• 3. Whether the reasons recorded for reopening the assessment were valid.

Judgment Outcome

Decided in favour of Assessee.

Precedents Relied Upon

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