This analysis covers the appeal filed by Hardik Rao against the CIT(A)-24, New Delhi’s decision for the 2016-17 assessment year. The tribunal’s deliberations and ruling provide significant insights into procedural and legal standards applicable to income tax assessments.
Hardik Rao challenged the legality of the assessment process, particularly the application of Section 153C of the IT Act, claiming it was barred by limitation and lacked incriminating material warranting the tax additions made.
The tribunal addressed the appeal by focusing primarily on the adherence to legal procedures, including the mandatory issuance of notices and the proper application of tax laws. The question of whether the assessment was supported by substantive evidence was critically evaluated.
The final tribunal order highlighted the necessity of adhering to legal protocols, such as the mandatory Document Identification Number (DIN) as required by CBDT Circular No. 19/2019. The decision to nullify the assessment due to procedural non-compliance underlines the judiciary’s strict stance on the adherence to procedural justice and legal norms.
Order pronounced in the open court on 2023-07-20.
Detailed Analysis of Hardik Rao’s Income Tax Appeal for AY 2016-17
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