ITA 587/DEL/2019 addresses the appeal by Vijayshree Food Products P.Ltd against the reassessment order by the CIT(A)-30, New Delhi, for the assessment year 2014-15. The case involves intricate legal discussions on the validity of reassessment proceedings under Section 147 of the Income Tax Act, focusing on the role of third-party statements and procedural adherence by the tax authorities.
The appeal challenges the decision made by the CIT(A) which confirmed the reopening of the assessment based on alleged undisclosed share application money. The primary contention revolves around the adequacy of the reasons provided for reassessment and the procedural lapses in handling third-party evidences.
Key issues include the reliance on third-party statements without providing an opportunity for cross-examination, and the implications of such reliance on the validity of the reassessment. The case also explores the principle of natural justice in the context of tax reassessments.
The Tribunal’s decision to set aside the reassessment on grounds of insufficient evidence and procedural irregularities highlights the critical need for robust reasoning and procedural fairness in tax proceedings. The judgment serves as a precedent on the standards required for initiating reassessments under Section 147.
Reassessment Challenges in ITA 587/DEL/2019: Vijayshree Food Products P.Ltd vs. ACIT
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