The assessing officer has to decide the issues involved before

The assessing officer has to decide the issues involved before 

The assessing officer has to decide the issues involved before him on its merit and cannot passed the assessment order only based on the admissions/surrender made by the assessee representative. He ought to have decided the matter on merit in accordance with law, not based on the admission or refusal of the assessee. Also the principle of estoppels is not applicable to income tax proceedings and the authorities should bear in mind that the right income of the assessee to be taxed in the right assessment year and well within the limitation as prescribed in the Act. (ITAT bench of Delhi, date of order 09.01.2023)


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