SHANTARAM PARSHURAM PATIL,PUNE vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE 12, PUNE, PUNE

आदेश /ORDER

PER Dr. DIPAK P. RIPOTE, A.M : This is an appeal filed by the assessee against the order of the Learned Commissioner of Income Tax (Appeals), NFAC, Delhi [Ld.CIT(A)], passed u/s. 250 of the Income Tax Act, 1961 (‘the Act’) for AY 2020-21 on 25.02.2026, emanating from the Assessment Order u/s 147 r.w.s. 144 r.w.s. 144B of the Act, dated 13.02.2025.

Submission of Ld. AR : 2. In this case, the Ld. AR filed paper book containing 23 pages. The Ld. AR vehemently submitted that the Assessing Officer (AO) had issued notices on email id which was defunct. The Ld. AR further submitted that the email id appearing in the Income Tax Portal is different and the notices has been sent by

ITA No. 2158/PUN/2026 the AO on different email id. The Ld. AR invited our attention to page No. 23 of the paper book which is e-proceedings sheet to demonstrate the same.

2.1 The Ld. AR submitted that therefore the assessee could not file requisite details as called for by the AO. The Ld. AR submitted that the Ld. CIT(A) has not considered the request of the assessee.

2.2 The Ld. AR also submitted that the AO has not provided copy of the reasons recorded for re-opening. The Ld. AR requested that the assessee may be provided one more opportunity to file all the details.

Submission of Ld. DR : 3. The Ld. DR relied on the order of the Assessing Officer and the Ld. CIT(A).

Findings and analysis: 4. We have heard both the parties and perused the record. In this case, it is observed that the assessment order was passed u/s 147 r.w.s. 144 r.w.s. 144B of the Act for AY 2020-21. The assessee had filed return of income u/s 139(1) of the Act declaring total income at Rs.33,47,730/- for AY 2020-21. Based on the information received by the AO, the AO issued notice u/s 148 of the Act dated 28.03.2024. It is observed that the AO in the reassessment order has considered all the credit entries appearing in Bank of Maharashtra Account of the assessee as turnover of the assessee. The assessee pleaded that all the credit entries do not reflect receipts of the assessee. However, it is a fact that the assessee had not filed the

ITA No. 2158/PUN/2026 documents to substantiate its claim during the assessment proceedings. Before the Ld. CIT(A), the assessee pleaded that the case may be set aside to AO or opportunity may be provided to the assessee to file all the details. It is observed that the Ld. CIT(A) issued three notices and then upheld the assessment order. In this case, the assessee has failed to file details because of the notices being served on the email id which was not in used. It is also submitted by the Ld. AR that the Reasons recorded for re-opening were not provided. Hon’ble Bombay High Court in the case of Sahebrao Deshmukh Co-op. Bank Ltd. Vs. ACIT, (2023) 149 taxmann.com 248 (Bombay) has held that it is mandatory to provide copy of reasons recorded for re- opening.

Order pronounced in the open Court on 18th August, 2026

Sd/- Sd/- (PAVAN KUMAR GADALE) (Dr. DIPAK P. RIPOTE) JUDICIAL MEMBER ACCOUNTANT MEMBER पुणे/Pune; दिन ांक/Dated : 18-08-2026 Ravi Digitally signed by Ravi Kumar Ravi Kumar Kumar Date: 2026.08.19 15:18:09 +05'30'

ITA No. 2158/PUN/2026

आदेश की प्रतितिति अग्रेतिि/Copy of the Order is forwarded to: 1. अपील र्थी / The Appellant 2. प्रत्यर्थी / The Respondent 3. The concerned Pr. CIT, Pune 4. DR, ITAT, ‘B’ Bench, Pune 5. ग र्ड फ ईल / Guard file. आदेशानुसार/ BY ORDER, // True Copy // Assistant Registrar आयकर अपीलीय अदिकरण,पुणे / ITAT, Pune