SHRI NILESH HARILAL MANEK,AHMEDABAD vs. THE ITO WARD 2 (3), PORBANDAR

ITA 857/RJT/2024Status: DisposedITAT Rajkot08 September 2026AY 2009-108 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that the reassessment proceedings under Section 147 were invalid as the reasons recorded did not clearly establish the income that had escaped assessment. Consequently, the assessment order was quashed.

What were the facts?

The assessee purchased an immovable property for Rs. 50,00,000/- without filing a return of income. The Assessing Officer reopened the assessment and added the entire amount as unexplained investment. The CIT(A) accepted the source of investment but taxed the long-term capital gain from another property sale.

What were the issues?

Whether the reassessment proceedings initiated under Section 147 were validly conducted based on the reasons recorded by the Assessing Officer.

Which sections of the Income-tax Act were involved?

Section 147,Section 144,Section 148,Section 142(1),Section 271(1)(c),Section 271(1)(b)

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 D. M. Rindani, Ld. AR
For Respondent: Shri Ganesh Iyer, Ld. Sr. DR
Hearing: 01/09/2026Pronounced: 08/09/2026

Per, Shri Sonjoy Sarma, JM: The instant appeal, being ITA No. 857/Rjt/2024 for the assessment year 2009- 10, has been filed by the assessee against the order of the L

The order continues below.

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