Vilayil Satyan Pillai vs Assessment Unit, NFAC Delhi

Parties Involved

Facts Summary

The assessee’s case was re-opened under section 147 and income was assessed at Rs. 43,27,44,406/- as against returned income of Rs. 6,18,583/- vide order dated 29.05.2023 passed under section 147 read with section 144B of the Income Tax Act, 1961. Aggrieved by this order, the assessee preferred an appeal before the Learned Commissioner of Income Tax (Appeals). As no compliance was made to the multiple notices issued during the course of appellate proceedings, the appeal was dismissed ex-parte vide order dated 21.01.2025. Further aggrieved, the assessee has filed an appeal before the Tribunal. The assessee has remained non-compliant throughout the proceedings before the lower authorities.…

Legal Issues

• 1. Whether the Ld. National Faceless Appeal Centre (NFAC) erred in confirming the addition of Rs. 43,21,25,823/- made in the re-assessment order.
• 2. Whether the addition of Rs. 43,21,25,823/- as commission income was valid.
• 3. Whether the re-assessment proceeding under section 147 was illegal and invalid.
• 4. Whether the re-assessment proceeding under section 147 was invalid due to non-compliance with mandatory procedures.

Judgment Outcome

Decided in favour of Assessee.

Precedents Relied Upon

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