PRAKASH POPATLAL PARMAR,RAJKOT vs. THE INCOME TAX OFFICER WARD-2(2)(1), RAJKOT, RAJKOT

ITA 896/RJT/2026Status: DisposedITAT Rajkot21 September 2026AY 2019-202 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that the reopening of assessment was based on vague and non-incriminating information from a third-party search without establishing a live link to the assessee's income. The addition was made without proper confrontation and cross-examination, violating principles of natural justice.

What were the facts?

The assessee's case was reopened based on information from a third-party search (RK Group). The Assessing Officer added Rs. 5,00,000/- as unexplained investment, which was upheld by the CIT(A). The assessee argued the reopening was based on vague information and lacked a direct link to his income.

What were the issues?

Whether the reopening of assessment based on third-party information without a direct link to the assessee's income is valid. Whether the addition of unexplained investment is justified without proper evidence and adherence to natural justice principles.

Which sections of the Income-tax Act were involved?

Section 69,Section 147,Section 148

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, “SMC”

Before: Dr. Arjun Lal Saini

For Appellant: Shri Brijesh Parekh, Ld. AR
For Respondent: Shri Shishir Kumar, Ld. Sr. DR
Hearing: 30/07/2026Pronounced: 21/09/2026

Per, Dr. Arjun Lal Saini, AM: Captioned appeal filed by the assessee, pertaining to assessment year (AY) 2019-20, is directed against the order under section 250 of the Income- tax Act, 1961 (hereinafter referred to as ‘the Act’) passed by the National Faceless Appeal Centre (NAC) Delhi/Commissioner of Income-tax (Appeals) [in short ‘NFAC/Ld.CIT(A)’], dated 22.10.2025, which in turn arises out of an assessment order passed by the Assessing Officer u/s 147 of the Act, dated 27.03.2024. 2. The grounds of appeal raised by

The order continues below.

Read the full judgment

A free account opens 10 full judgments a month. Re-reading one you have already opened does not count again.

Create a free accountSign in

See plans and prices

The summary, the parties, the sections and the citations above are open to everyone and always will be. Only the text of the order and the PDF are metered.

More judgments on Section 69

All 9,011 judgments and leading authorities on Section 69 →

Recent GST High Court judgments

Search GST case law →