GUNVANTBHAI NATHUBHAI PATEL,NA

ITA 511/SRT/2026Status: DisposedITAT Surat10 August 2026AY 2012-135 pages
AI SummaryRemanded

What did the Tribunal hold?

The Tribunal noted the assessee's non-compliance but also the lack of adequate opportunity before the CIT(A). It was decided that the matter should be referred to the Departmental Valuation Officer (DVO) for valuation.

What were the facts?

The assessee did not file an income tax return for AY 2012-13. The Assessing Officer (AO) reopened the assessment based on information about an immovable property sale, making additions for sale consideration and the difference between sale value and stamp duty value. The CIT(A) confirmed the AO's actions.

What were the issues?

Whether the reopening of assessment was valid and whether the additions made under Section 50C were justified without a DVO report. The Tribunal also considered the opportunity of being heard.

Which sections of the Income-tax Act were involved?

Section 147,Section 148,Section 144,Section 50C,Section 271(1)(c)

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, “SMC”

Before: Dr. Arjun Lal Saini

For Appellant: Shri P M Jagasheth, CA
For Respondent: Shri Ajay Uke, Sr. DR
Hearing: 18/05/2026

Per, Dr. Arjun Lal Saini, AM: Captioned appeal filed by the assessee, pertaining to Assessment Year 2012- 13, is directed against the order passed under section 250 of the Income Tax Act, 1961 (hereinafter referred to as “the Act”) by Commissioner of Income-tax (Appeals), National Faceless Appeal Centre (NFAC) Delhi, dated 19.01.2026, which in turn arises out of an order passed by the Assessing Officer u/s 144 r.w.s. 147 of the Act, on 30.11.2019. 2. The grounds of appeal raised by the assessee are as follows:

1.

On the facts and circumstances of the case as wel

The order continues below.

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