RASIKBHAI POPATBHAI KATHIRIYA,RAJKOT vs. ITO, WARD-2(1)(1), RAJKOT, RAJKOT

ITA 938/RJT/2026Status: DisposedITAT Rajkot09 September 2026AY 2020-216 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that the reassessment proceedings were invalid due to the lack of a manually or digitally signed approval under Section 151 of the Act. Consequently, the reassessment order was quashed.

What were the facts?

The assessee's appeal concerns an addition of Rs. 33,86,000/- made by the Assessing Officer (AO) on account of alleged 'on-money' payment for a property. The Commissioner of Income Tax (Appeals) confirmed this addition. The assessee challenged the validity of the reassessment proceedings initiated under Section 147 of the Income Tax Act.

What were the issues?

The primary issue was the validity of reassessment proceedings initiated without a properly authenticated approval under Section 151. The secondary issue involved the addition made on account of alleged 'on-money' payment.

Which sections of the Income-tax Act were involved?

Section 147,Section 151,Section 282A,Section 69A,Section 115BBE

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, “SMC”

Before: Dr. Arjun Lal Saini

For Appellant: Shri Mehul Ranpura. 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) 2020-21, is directed against the order passed under section 250 of the Income-tax Act, 1961 (hereinafter referred to as ‘the Act’) dated 29.04.2026 by the National Faceless Appeal Centre (NFAC), Delhi/Commissioner of Income Tax (Appeals) [in short ‘Ld.CIT(A)’] which in turn arises out of an assessment order passed by the Assessing Officer (in short ‘AO’) u/s 147 of the Act, dated 17.03.2025. 2. Ground

The order continues below.

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