RAMESHBHAI BHAGAWANBHAI DOBARIYA,MUMBAI vs. INCOME TAX OFFICER, WARD 3(2)(1), SURAT, SURAT

ITA 397/SRT/2026Status: DisposedITAT Surat10 August 2026AY 2020-2112 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that the assessee had discharged the onus of proving the identity, genuineness, and creditworthiness of the lenders by providing confirmations, ITR acknowledgments, and bank statements. The Tribunal found that Vishnu Traders and Vinayak Traders were merely conduits for payments from the actual lenders, who were relatives of the assessee.

What were the facts?

The assessee purchased an immovable property and claimed the source of funds as unsecured loans from various parties. The Assessing Officer treated a sum of Rs. 25,05,550/- as unexplained investment, doubting the genuineness of the loans from two specific parties, Vishnu Traders and Vinayak Traders.

What were the issues?

Whether the addition of Rs. 25,05,550/- as unexplained investment was justified when the assessee provided evidence of unsecured loans from relatives, routed through two trading entities.

Which sections of the Income-tax Act were involved?

Section 69

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, “SMC”

Before: Dr. Arjun Lal Saini

For Appellant: Shri Sapnesh Sheth, Advocate
For Respondent: Shri Ajay Uke, Ld. Sr. DR
Hearing: 19/05/2026

Per, Dr. Arjun Lal Saini, AM: Captioned appeal filed by the assessee, pertaining to assessment year (AY) 2020-21, is directed against the order passed under section 250 of the Income-tax Act, 1961 (hereinafter referred to as ‘the Act’) dated 16.02.2026 by the National Faceless Appeal Centre (NFAC), Delhi/Commissioner of Income Tax (Appeals) [in short ‘Ld. CIT(A)’] which in turn arises out of an assessment order passed by the Assessing Officer (in short ‘AO’) u/s. 143(3) of the A

The order continues below.

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