RAMESHBHAI TRIKAMBHAI GORI,RAJKOT vs. INCOME TAX OFFICER WARD -2(1)(1), RAJKOT

ITA 164/RJT/2026Status: DisposedITAT Rajkot11 September 2026AY 2016-177 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that since the assessee had no bank account with the cooperative society in question, the addition made by the Assessing Officer was baseless. Consequently, the penalty imposed also lacked foundation.

What were the facts?

The Assessing Officer reopened the assessment based on information that the assessee had made significant financial transactions without filing a return. An addition of Rs. 3,30,56,200/- was made as unexplained investment/cash credit. The assessee appealed this addition and a penalty.

What were the issues?

Whether the addition of unexplained investment is justified when the assessee denies having any account with the society. Whether the penalty under Section 271(1)(b) is sustainable if the primary addition is deleted.

Which sections of the Income-tax Act were involved?

Section 147,Section 271(1)(b),Section 148,Section 142(1),Section 151,Section 148A

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, Rajkot Bench, Rajkot

Before: Dr. Arjun Lal Saini & Shri Sonjoy Sarma

For Appellant: Shri R. D. Lalchandani, Ld. AR
For Respondent: Shri Ravinder Sindhu, Ld. CIT (DR) and Ganesh Iyer, Ld. Sr. DR
Hearing: 24/08/2026

Per, Dr. Arjun Lal Saini, AM: Captioned two appeals filed by the assessee, pertaining to assessment year (AY) 2016-17, are directed against the separate orders 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 27.01.2026, which in turn arise out of an assessment order passed by the Assessing Officer u/s 147 of the Act, da

The order continues below.

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