Date of Hearing: 12.09.2023
Date of Pronouncement: 29.09.2023
This case involves the reassessment proceedings initiated against the appellant, Ruby Singh, under section 147 of the Income Tax Act for the assessment year 2018-19. The reassessment was prompted by the alleged nondisclosure of income facts, leading to the evasion of tax.
The appellant, represented by legal counsel, contested the reassessment proceedings arguing the lack of valid jurisdiction and inappropriate initiation of proceedings under section 147. The respondent, DCIT, upheld the proceedings citing sufficient ‘reason to believe’ based on tangible material that income had escaped assessment.
The tribunal examined the merits of the reassessment proceedings, particularly focusing on the validity of the proceedings under section 147. After reviewing the arguments and evidence, the tribunal upheld the initiation of the reassessment proceedings, dismissing the appellant’s appeal. The tribunal’s decision emphasized the proper application of legal standards and the sufficiency of the ‘reason to believe’ that income had escaped assessment.
The tribunal’s order highlights the importance of adhering to procedural requirements and the necessity for the assessing officer to possess adequate reasons backed by evidence before initiating reassessment. This case reaffirms the judiciary’s stance on maintaining rigorous standards in tax reassessment cases.
Case Summary: Ruby Singh vs. DCIT, Central Circle-8, New Delhi – ITA 2880/DEL/2022
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