KIRAN JITENDRAKUMAR SIDDHPURA,RAJKOT vs. ITO WARD 2(1)(2) RAJKOT, RAJKOT

ITA 823/RJT/2026Status: DisposedITAT Rajkot08 September 2026AY 2019-2011 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal condoned the delay in filing the appeal. Following a co-ordinate bench's decision, the addition made on the basis of an unsigned excel sheet without providing an opportunity for cross-examination was deleted.

What were the facts?

The assessee's appeal was filed 22 days late due to a tax consultant's failure to inform them of the proceedings. The addition of Rs. 33,05,720/- was made on account of unexplained investment based on an excel sheet found at a third party's premises.

What were the issues?

Whether additions can be made based on unsigned documents found at third-party premises without providing an opportunity for cross-examination. Whether the assessee, being a non-resident, is liable for tax on income not accrued or arisen in India.

Which sections of the Income-tax Act were involved?

Section 147,Section 69A,Section 115BBE,Section 272A(1)(d),Section 271AAC,Section 234A,Section 234B,Section 234C,Section 234D

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, “SMC”

Before: Dr. Arjun Lal Saini

Hearing: 18/06/2026Pronounced: 08/09/2026

Per, Dr. Arjun Lal Saini, AM: The present appeal has been filed by the assessee, against the order passed by the Learned Commissioner of Income Tax (Appeal), National Faceless Appeal, Centre (NFAC), Delhi [hereinafter referred to as “CIT(A)”] dated 18.02.2026 arising in the matter of assessment order passed u/s.147 of the Income Tax Act, 1961 dated 27.03.2024 relevant to the Assessment Year 2019-20. 2. The appeal filed by the assessee is barred by limitation by 22 days before the Tribunal. When the matter was called for hearing,

The order continues below.

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