JYOTI CHALLANI,INDORE vs. INCOME TAX OFFICER-5(1), INDORE, INDORE

ITA 447/IND/2026Status: DisposedITAT Indore10 August 2026AY 2023-2415 pages
AI SummaryRemanded

What did the Tribunal hold?

The Tribunal found that the assessee was non-participative in the appellate proceedings before the CIT(A). Therefore, the Tribunal set aside the CIT(A)'s order and remanded the matter back for de novo consideration.

What were the facts?

The Assessing Officer (AO) added Rs. 36,15,837/- to the assessee's income as deemed interest on loans advanced without charging interest. The assessee contended that she follows the cash method of accounting and the loans were out of own funds. The CIT(A) upheld the AO's addition.

What were the issues?

Whether the CIT(A) erred in upholding the addition of deemed interest without proper adjudication, and whether the assessee's non-participation warranted a remand.

Which sections of the Income-tax Act were involved?

Section 143(3),Section 145(3),Section 250,Section 253,Section 246A,Section 56

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, INDORE BENCH, INDORE

Before: SHRI MANISH BORAD & SHRI PARESH M. JOSHI

For Appellant: CA &
Pronounced: 10.08.2026

Per Paresh M. Joshi, JM:

This is an Appeal filed by the Revenue under section 253 of the Income tax Act 1961,[ herein after referred to as the Act

for the sake of brevity] before this tribunal. The Revenue is aggrieved by the order bearing No:-ITBA/NFAC/S/250/2025-

26/1085071865(1) dated 21.01.2026 passed by the Ld.

CIT(A) u/s 250 of the Act which is hereinafter referred as the Jyoti Challani ITA No. 447/Ind/2026 AY-2023-2024 “Impugned Order”. The Relevant Assessment Year is 2023-

2024 and the corresponding Previous Period is from 01/04/2022 to 31/03/2023. 2. FACTUAL MATRIX

2.

1 That as and by way of an Assessment Order made u/s 143(3)

RWS 144B of the Act, th

The order continues below.

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