PRASHANTKUMAR CHIMANLAL PATEL,MEHSANA,GUJARAT vs. ITO,INT TAX-WARD 2, AHMEDABAD

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ITA 756/AHD/2026Status: DisposedITAT Ahmedabad13 August 2026AY 2020-213 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that the CIT(A) was not justified in confirming the addition of Rs. 2,49,000/-. The assessee had provided affidavits from the loan giver and his father, acknowledging the payments and explaining their sources.

What were the facts?

The Assessing Officer made an addition of Rs. 1,05,05,482/- on account of unexplained credits in the assessee's bank accounts. The CIT(A) confirmed an addition of Rs. 2,49,000/- while deleting the rest based on a remand report.

What were the issues?

Whether the CIT(A) was justified in confirming additions on account of unexplained credits when the assessee provided supporting evidence and affidavits for the amounts in question.

Which sections of the Income-tax Act were involved?

Section 250

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, “D” BENCH, AHMEDABAD

Before: SHRI SANJAY GARG & SMT. ANNAPURNA GUPTA

For Appellant: Smt. Nirha Desai, A.R, Shri Rameshwar P Meena, Sr.DR
For Respondent: Shri Rameshwar P Meena, Sr.DR
Hearing: 18/05/2026

IN THE INCOME TAX APPELLATE TRIBUNAL “D” BENCH, AHMEDABAD

BEFORE: SHRI SANJAY GARG, JUDICIAL MEMBER AND SMT. ANNAPURNA GUPTA, ACCOUNTANT MEMBER आयकर अपील सं./I.T.A. No. 756/Ahd/2026 (िनधा�रण वष� / Assessment Year : 2020-21) बनाम Prashantkumar Chimanlal Income Tax Officer / Patel Int. Tax-Ward-2, Vs. 2-88, Patel Vas-1, Ransipur, 210, Navjeevan Press Mehsana, Gujarat-382870 Building, Ashram Road, Ahmedabad, Gujarat - 380014 �थायी लेखा सं./जीआइआर सं./PAN/GIR No. : AMCPP4910G (Appellant) .. (Respondent) अपीलाथ� ओर से /Appellant by : Smt. Nirha Desai, A.R. ��यथ� क� ओर से/Respondent by : Shri Rameshwar P Meena, Sr.DR

Date of Hearing 18/05/2026 13/08/2026 Date of Pronouncement

(आदेश)/ORDER Per Sanjay Garg, Judicial Member:

The present appeal has been preferred by the assessee against the order of the Ld. Commissioner of Income Tax (Appeals)-13, Ahmedabad (hereinafter referred to as “CIT(A)”), dated 07.01.2026 passed under Section 250 of the Income Tax Act, 1961 (hereinafter referred to as the “Act”) and relates to Assessment Year (A.Y.) 2020-21.

ITA No.756/Ahd/2026 [Prashantkumar Chimanlal Patel vs. ITO] A.Y. 2020-21 - 2 –

2.

The assessee, in this appeal, is aggrieved by the action of the Ld. CIT(A) in confirming the addition to the extent of Rs.2,49,000/-, out of total addition made by the Assessing Officer (in short ‘the AO’) of Rs.1,05,05,482/- on account of unexplained credits in the bank accounts of the assessee.

3.

The Ld. AO had made the impugned addition as the assessee had failed to explain the source of credits in his bank accounts. However, before the Ld.CIT(A), the assessee explained the source of the credits, whereupon, the Ld. CIT(A) called remand report from the AO and considering the remand report, the Ld. CIT(A) deleted the addition to the extent of Rs.1,02,56,482/- accepting the explanation of the assessee regarding the source of the deposits. However, the Ld. CIT(A) confirmed the addition in respect of Rs.2 Lakhs, claimed by the assessee to have been received from one Shri Jatinkumar Kantilal Shah, on account of repayment of loan, earlier given by the assessee to him. The Ld. CIT(A) also confirmed the addition of Rs.49,000/-, which, the assessee has claimed to have received as gift from his father.

4.

So far as the amount of Rs.2 Lakhs received from Shri Jatinkumar Kantilal Shah is concerned, the assessee duly furnished the affidavit of the said person, who confirmed that the said amount was remitted by him into the bank account of the assessee, which was on account of repayment of earlier loan taken.

ITA No.756/Ahd/2026 [Prashantkumar Chimanlal Patel vs. ITO] A.Y. 2020-21 - 3 –

5.

So far as the cash credits of Rs.49,000/- is concerned, the assessee has furnished the affidavit of his father, wherein, he has duly deposed that the said amount was given by him to the assessee, the source of which, was his agricultural income and accumulated household savings.

6.

Considering the smallness of the amounts and the payers having duly acknowledged the payment of the said amount to the assessee, we do not find justification on the part of the Ld. CIT(A) in confirming the impugned addition and the same is, accordingly, ordered to be deleted.

7.

In the result, the appeal of the assessee stands allowed.

This Order pronounced on 13/08/2026 under Rule 34(4) of the ITAT Rules, 1963

Sd/- Sd/- (ANNAPURNA GUPTA) (SANJAY GARG) ACCOUNTANT MEMBER JUDICIAL MEMBER Ahmedabad; Dated 13/08/2026 S. K. SINHA True Copy आदेश क� �ितिल�प अ�े�षत/Copy of the Order forwarded to : अपीलाथ� / The Appellant 1. ��यथ� / The Respondent. 2. 3. संबंिधत आयकर आयु� / Concerned CIT आयकर आयु�(अपील) / The CIT(A)- 4. 5. �वभागीय �ितिनिध, आयकर अपीलीय अिधकरण, अहमदाबाद / DR, ITAT, Ahmedabad 6. गाड� फाईल / Guard file. आदेशानुसार/ BY ORDER,

उप/सहायक पंजीकार (Dy./Asstt. Registrar) आयकर अपीलीय अिधकरण, अहमदाबाद / ITAT, Ahmedabad

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