NEERAJ BHATIA,FARIDABAD vs. INCOME TAX OFFICER, WARD-2(1), FARIDABAD
What did the Tribunal hold?
The Tribunal noted the assessee's failure to respond to notices and the large value of transactions. Considering the assessee's potential incarceration, the matter was set aside and remitted back to the CIT(A) for fresh adjudication.
What were the facts?
The assessee's case was reopened due to significant financial transactions and failure to file a return. Additions were made for unexplained money and expenditure, and large cash deposits, as the assessee failed to provide adequate documentation.
What were the issues?
Whether the additions made by the AO for unexplained money and expenditure were justified, and whether the CIT(A) correctly dismissed the appeal without proper assessee representation.
Which sections of the Income-tax Act were involved?
AI-generated summary — verify with the full judgment below
Income Tax Appellate Tribunal, DELHI BENCH “G” NEW DELHI
Before: SHRI SATBEER SINGH GODARA & SHRI SANJAY AWASTHI
ITA No.6446/DEL/2026 NEERAJ BHATIA, FARIDABAD IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH “G” NEW DELHI BEFORE SHRI SATBEER SINGH GODARA, JUDICIAL MEMBER AND SHRI SANJAY AWASTHI, ACCOUNTANT MEMBER ITA No.6446/DEL/2026 Assessment Year: 2020-21 NEERAJ BHATIA, Vs. INCOME TAX OFFICER, 934, Sector 15A, Faridabad 121007, Income Tax Office, Ward 2(1), CGO Haryana. Complex, NH-4, NIT Faridabad PAN No.ABCPB9309E 121001, Haryana. Appellant Respondent Assessee by None Revenue by Ms. Kranti, CIT DR Date of hearing: 01.09.2026 Pronouncement on 01.09.2026 O R D E R PER SANJAY AWASTHI, ACCOUNTANT MEMBER: 1. This appeal arises from order dated 22.04.2026, passed u/s 250 of the Income Tax Act, 1961 (hereafter as “the Act”), by NFAC.
1.1 In this case, the assessee’s case was reopened u/s 147 of the Act on the basis of information that there were financial transactions to the tune of Rs.311,85,740/- in the name of the assessee. It was found that the assessee had not filed any return of income for the year under consideration. Before the Ld. AO the assessee either did not respond to opportunities provided or filed partial details. Thereafter, the Ld. AO treated an amount of Rs.46,83,430/- as unexplained money u/s 69A of the Act. It is seen that a second addition of Rs.9,76,310/- was also made as unexplained expenditure u/s 69C of the Act. The third and last issue in 1
ITA No.6446/DEL/2026 NEERAJ BHATIA, FARIDABAD this case was cash deposits amounting to Rs.11,78,63,867/- during the year under consideration. In this regard the assessee apparently failed to provide appropriate evidence and documents and therefore this amount was also added u/s 69A of the Act as unexplained money.
1.2 The assessee carried this matter before the ld. CIT(A) where he did not comply to any of the notices issued by the Ld. CIT(A) and this fact is recorded in para 5.3 at pages 4 to 5 of the impugned order. Thereafter, the Ld. CIT(A) confirmed the additions made by the Ld. AO and dismissed the appeal.
1.3 On the last date of hearing, none appeared on behalf of the assessee but it was decided to proceed ahead with the adjudication, with the help of Ld. DR.
The Ld. DR took us through the assessment order and pointed out that the return of income filed by the assessee in response to notice u/s 148 of the Act (filed on 20.02.2025), did not satisfactorily explain the very large value transactions shown in his account. On a consideration of the facts and circumstances of the case, and the fact that the assessee is apparently incarcerated in criminal proceedings (as gleaned from the grounds of appeal), we are inclined to set aside the impugned order and remit this matter back to the file of the Ld. CIT(A) for fresh adjudication. The assessee would do well to ensure proper representation before the Ld. CIT(A) so that his correct income would be determined. 2
ITA No.6446/DEL/2026 NEERAJ BHATIA, FARIDABAD 3. In the result, the appeal is partly allowed for statistical purposes.
Order pronounced in the open court on 01.09.2026
Sd/- Sd/- (SATBEER SINGH GODARA) (SANJAY AWASTHI) JUDICIAL MEMBER ACCOUNTANT MEMBER Dated: 16.09.2026 *Kavita Arora, Sr. P.S. Copy forwarded to: 1. Appellant 2. Respondent 3. CIT 4. CIT(Appeals) 5. DR: ITAT ASSISTANT REGISTRAR ITAT, NEW DELHI
More judgments on Section 147
- ACIT Central Bilaspur, Bilaspur vs Arun Kumar Agrawal, SaktiITSSA 26/RPR/2025[2018-19]Status: Disposed21 Oct 2026AY 2018-19
- Vinod Agrawal, Kawardha vs Assisstant Commissioner of Income Tax…ITA 666/RPR/2026[2019-20]Status: Heard21 Oct 2026AY 2019-20
- Sar Business Tradelink Private Limited… vs Income Tax Officer, Ward - 1(2), RaipurITA 599/RPR/2026[2014-15]Status: Heard21 Oct 2026AY 2014-15
- Tarunaben Maganlal Bhut, Navagam vs ITO Ward 2(2)(1), RajkotITA 673/RJT/2026[2024-25]Status: Disposed21 Oct 2026AY 2024-25
- Neo Incorporation, Rajkot vs DCIT Circle- 1(2), RajkotITA 471/RJT/2026[2012-2013]Status: Disposed21 Oct 2026AY 2012-2013
Recent GST High Court judgments
Search GST case law →- Basant Kumar Gupta vs. Union Of INDIAPatna · 2 Nov 2026
- M/S Swapnashiyana Homes Developers Private Limited vs. The Union Of INDIAPatna · 2 Nov 2026
- M/S B.K. Agency Under The Proprietor Of Bhola Prasad vs. The Chief Commissioner, CGSTPatna · 2 Nov 2026
- Jashim Uddin vs. The State Of Assam And 5 OrsGauhati · 1 Nov 2026
- Mohammed Khadeer Baig vs. The State Of Andhra PradeshAndhra Pradesh · 1 Nov 2026