PARESH DEVABHAI PANCHAL,AHMEDABAD, GUJARAT vs. ITO WARD 2(1)(2), AHMEDABAD, AHMEDABAD, GUJARAT

ITA 1018/AHD/2026Status: DisposedITAT Ahmedabad22 September 2026AY 2019-206 pages
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What did the Tribunal hold?

The Tribunal held that while the reopening of assessment was in order, the addition made by the AO was based on presumptions and lacked specific corroborative evidence linking the assessee to the alleged cash payment. Therefore, the addition could not be sustained.

What were the facts?

The assessee's case was selected for reassessment based on information from a builder's search action, alleging on-money payment for a jointly purchased property. The Assessing Officer (AO) added the alleged on-money amount to the assessee's income, which was upheld by the CIT(A).

What were the issues?

Whether the reassessment proceedings were validly initiated and whether the addition of unexplained investment was supported by sufficient evidence, or if it was based on mere assumptions and presumptions.

Which sections of the Income-tax Act were involved?

Section 147,Section 148,Section 148A,Section 151,Section 69,Section 115BBE,Section 234B,Section 234C,Section 271AAC

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, AHMEDABAD “SMC” BENCH

Before: Shri Sanjay Garg & Shri R. Govindarajan

For Appellant: Shri Chetan Agrawal, A.R
For Respondent: Ms. Madhulika Satpute, Sr. D.R

PER R. GOVINDARAJAN, ACCOUNTANT MEMBER:

The assessee has filed the appeal against the order dated 22-01- 2026 passed by Commissioner of Income Tax (Appeals), National Faceless Appeal Centre NFAC (in short, referred to as the CIT(A)) u/s. 250 of the Income Tax Act, 1961 (herein referred to as “the Act”) relating to Assessment Year 2019-20. Condonation of delay

2.

There was delay of 4 days in filing of appeal before the Tribunal. Negligence on the part of tax consultant is cited as a reason for delay. In the interest of justice, delay is condoned. Paresh Devabhai Panchal, A.Y. 2019-20

3.

The assessee raised the following grounds of appeal:- “1. The Ld. CIT(

The order continues below.

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