PRAKASH VALJIBHAI PATEL,RAJKOT vs. THE INCOME TAX OFFICER, RAJKOT

ITA 863/RJT/2026Status: DisposedITAT Rajkot10 September 2026AY 2021-229 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that additions based solely on unsigned excel sheet data from a third party, without any corroborative evidence like registered deeds, payment trails, or builder's confirmation, are unsustainable. The denial of cross-examination also vitiated the proceedings.

What were the facts?

The assessee's income tax return for AY 2021-22 was initially filed normally. Reassessment proceedings were initiated based on information from a search action on the R.K. Group, which indicated alleged unaccounted investments by the assessee in a project developed by M/s Vivan Infraspace LLP.

What were the issues?

Whether additions can be made based on unsigned excel sheet data from a third party without corroborative evidence, and whether denial of cross-examination vitiates assessment proceedings.

Which sections of the Income-tax Act were involved?

Section 147,Section 151,Section 69,Section 115BBE,Section 139(1),Section 148,Section 143(3),Section 132(4A)

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. B. Shah, Ld. AR
For Respondent: Shri Shishir Kumar, Ld. Sr. DR
Hearing: 30/07/2026

Per, Dr. Arjun Lal Saini, AM: Captioned appeal filed by the assessee, pertaining to assessment year (AY) 2021-22, 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 25.05.2026, which in turn arises out of an assessment order passed by the Assessing Officer u/s 147 of the Act, dated 16.03.2026. 2. The grounds

The order continues below.

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