DINESH DHARAMDASANI,AHMEDABAD vs. THE ITO, WARD-1(2)(1), AHMEDABAD
Facts
The assessee's appeal was against an addition of Rs. 12,49,00,000/- as unexplained transactions with Renuka Mata Society. The CIT(A) upheld the addition and dismissed the appeal ex parte, stating the assessee failed to furnish substantial details.
Held
The Tribunal observed that the assessee failed to provide necessary details to the CIT(A). However, considering the assessee's plea for an opportunity to furnish documents and in the interest of justice, the matter was remanded for de novo adjudication.
Key Issues
Whether the addition of Rs. 12,49,00,000/- as unexplained transactions was justified, and whether the assessee had sufficient cause for not complying with notices.
Sections Cited
250
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Income Tax Appellate Tribunal, “A” BENCH, AHMEDABAD
Before: DR. B.R.R. KUMAR, VICE- & Ms SUCHITRA KAMBLE
PER DR. B.R.R. KUMAR, VICE-PRESIDENT:
- The captioned appeal has been filed by the assessee against the order passed by the Ld. Commissioner of Income-Tax (hereinafter referred to as “the Ld.CIT(A)”), National Faceless Appeal Centre (NFAC), Delhi vide order dated 12.11.2025 relevant to Assessment Year 2013-
The assessee has raised the following grounds of appeal:
1 The order passed by U/s.250 passed on 12.11.2025 for A.Y. 2013-14 by NFAC, [CIT(A)], Delhi (for short CIT(A)" upholding the addition of Rs.12,49,00,000/- as unexplained transaction in respect of Shri Renuka Mata Multi State Urban Co.Op. Credit Society Ltd. (for short "Renuka Mata Society") is wholly illegal, unlawful and against the principles of natural justice. - 2–
1 The Id. CIT(A), has grievously erred in law and or on facts in not considering fully and properly the submissions made and evidence produced before the FAO in respect of transaction claimed by FAO with Shri Renuka Mata Society.
2 The Ld. CIT(A) has failed to appreciate that there was a sufficient cause for failure to comply with the notices claimed to be issued by NFAC in as much as, the same were issued on the email id when the appellant was abroad.
1 The Id.CIT(A) has grievously erred in law and or on facts in upholding the addition of Rs.12,49,00,000/- as unexplained transactions in respect of Shri Renuka Mata Multi State Urban Co.Op. Credit Society Ltd.
2 That the in the facts and circumstances of the Id. CIT(A), ought not to have upheld the addition of Rs.12,49,00,000/- as unexplained transaction in respect of Shri Renuka Mata Multi State Urban Co.Op. Credit Society Ltd. It is, therefore, prayed that the addition of Rs. 12,49,00,000/- upheld by the CIT(A) may kindly be deleted.
Heard the argument of both the parties and perused the material available on record.
On perusal of the records, it is observed that the assessee was afforded multiple opportunities of hearing to furnish details, clarifications, and explanations to substantiate the source of unexplained cash deposits. However, assessee failed to furnish the substantial details or explanations before the Ld. CIT(A). Consequently, the Ld. CIT(A), based on the material available on record, upheld the action of the Assessing Officer and dismissed the appeal ex parte. - 3– the facts and in the interest of justice, we deem it appropriate to remand the matter to the file of the Ld.CIT(A) for conducting de novo adjudication. The assessee is directed to furnish all relevant documents, evidences, and bank details before the Revenue authorities and to comply with the notices issued by the revenue authorities without seeking unnecessary adjournments
In the result, the appeal of the assessee is allowed for statistical purposes.
The order is pronounced in the open Court on 27.03.2026. (SUCHITRA KAMBLE) VICE-PRESIDENT ()) Ahmedabad; Dated 27.03.2026 MV
आदेश की "ितिलिप अ"ेिषत/Copy of the Order forwarded to : 1. अपीलाथ" / The Appellant
""थ" / The Respondent. 3. संबंिधत आयकर आयु" / Concerned CIT 4. आयकर आयु"(अपील) / The CIT(A)- 5. िवभागीय "ितिनिध, आयकर अपीलीय अिधकरण, अहमदाबाद / DR, ITAT, Ahmedabad 6. गाड" फाईल / Guard file.
आदेशानुसार/ BY ORDER,सहायक पंजीकार (Dy./Asstt.
