SUNIL KUMAR,BANGALORE vs. THE INCOME TAX OFFICER, WARD - 6(3)(1), BANGALORE, BANGALORE

ITA 1428/BANG/2026Status: DisposedITAT Bangalore21 September 2026AY 2020-2110 pages
AI SummaryPartly Allowed

What did the Tribunal hold?

The Tribunal held that the Assessing Officer can make additions on issues that come to his notice during reassessment, even if they are different from the original reason for reopening, as per jurisdictional High Court precedent. However, the merits of the cash deposit addition were not properly examined by the lower authorities.

What were the facts?

The Assessing Officer reopened the assessment of the assessee for the purchase of a car. During reassessment, the AO noticed cash deposits of Rs. 32,87,500 in the assessee's bank account and made an addition on this basis, even though the reopening was for a different issue.

What were the issues?

Whether an AO can make additions on issues not forming the basis of reopening, and whether the addition for cash deposits was properly substantiated and examined on merits.

Which sections of the Income-tax Act were involved?

Section 147,Section 144B,Section 69A,Section 44AD,Section 148,Section 133(6),Section 250,Section 234B,Section 234D

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, BANGALORE BENCHES, BANGALORE

Before: SHRI PRASHANT MAHARISHI & SHRI SANDEEP SINGH KARHAIL

PER SHRI PRASHANT MAHARISHI, VICE PRESIDENT

01.

The Assessee has filed this appeal against the appellate order dated 7 January 2026 passed by the National Faceless Appeal Centre, Delhi [the learned CIT(A)] for assessment year 2020-21, dismissing the Assessee’s appeal against the reassessment order dated 6 January 2025 passed under section 147 read with section 144B of the Income Tax Act, 1961 [the Act] by the National Faceless Assessment Centre, Delhi [the learned AO].

ITA 1428/BA

The order continues below.

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