Sonti Soft Solutions Private Limited vs. ITO, Ward-3(1), Hyderabad

Parties Involved

Facts Summary

The assessee, Sonti Soft Solutions Private Limited, could not file its return of income for the assessment year 2017-18. The case was reopened under section 148 of the Income Tax Act, 1961 due to substantial interest income and cash deposits without filing a return. The Assessing Officer issued notices under section 142(1) of the Act on 30.09.2021 and 16.12.2021, which were not complied with by the assessee. Consequently, the assessment was completed under section 144 of the Act, resulting in an addition of Rs.3,23,16,332/-. The assessee appealed to the Commissioner of Income Tax (Appeals), but the appeal was dismissed ex-parte due to non-compliance with hearing notices. The matter was then brought before the Income Tax Appellate Tribunal.…

Legal Issues

• 1. Whether the Assessing Officer committed an error by overlooking the directions of the Hon'ble Supreme Court regarding the extension of the limitation period during the pandemic.
• 2. Whether the Commissioner of Income Tax (Appeals) failed to prove the service of notice of hearing to the assessee.
• 3. Whether the Commissioner of Income Tax (Appeals) overlooked the provisions of section 250(6) of the Income Tax Act, 1961.

Judgment Outcome

Decided in favour of Partly Assessee / Partly Revenue.

Precedents Relied Upon

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