RAJNIKUMAR RAMJIBHAI RABARI,SURAT vs. ITO, WARD 1(3)(1), SURAT

ITA 1116/SRT/2025Status: DisposedITAT Surat18 August 2026AY 2016-175 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that the assessee had provided sufficient explanation for the source of funds, including loan statements, cash in hand, and bank deposits. The Tribunal found contradictions in the AO's report and concluded that the addition made under Section 69 was not justified.

What were the facts?

The assessee purchased a luxury car for Rs. 98,90,000, taking a bank loan of Rs. 52,00,000 and leaving Rs. 46,90,000 unexplained. The Assessing Officer (AO) made an addition of Rs. 46,90,000 under Section 69 of the Income Tax Act, which was upheld by the CIT(A).

What were the issues?

Whether the addition of Rs. 46,90,000 as unexplained investment for the purchase of a luxury car was justified, and whether the reassessment proceedings were valid.

Which sections of the Income-tax Act were involved?

Section 69,Section 148,Section 147,Section 144

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, SURAT BENCH, SURAT

For Appellant: Shri Suresh K Kabra, CA
For Respondent: Shri Ashish Kumar, Sr.DR
Hearing: 16.06.2026Pronounced: 18.08.2026

PER : SUCHITRA KAMBLE, J M:

The appeal filed by the assessee is against the order passed by the Learned Commissioner of Income Tax (Appeals), National Faceless Appeal Centre (NFAC), Delhi [in short “CIT(A)”] dated 25.02.2025 for the Assessment Year (in short “AY”) 2016-17. 2. The assessee has raised the following grounds of appeal:

“1. The Ld. Faceless Assessing Officer has erred and was not just and proper on the facts of the case and in law in issuing Notice u/s 148 for time barred assessment year under of provision the amended 149 w.e.f. section 01/04/2021 in line with to decision of Rajeev Bansal (SC). Rajnikumar Ramjibhai

2.

The Ld. Faceless Assessing Officer ha

The order continues below.

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