RACHIT PRAMOD PODDAR,SURAT vs. ITO, WARD 3(2)(6), SURAT

ITA 564/SRT/2025Status: DisposedITAT Surat07 August 2026AY 2019-209 pages
AI SummaryRemanded

What did the Tribunal hold?

The Tribunal found factual inconsistencies in the AO's order regarding the nature of transactions and the entities involved. It noted that the material relied upon for re-opening was not fully furnished to the assessee, denying them an effective opportunity to explain.

What were the facts?

The assessee's income was re-assessed based on information suggesting fictitious share purchases. The Assessing Officer (AO) made an addition of Rs. 55,04,175/- as unexplained investment, which was confirmed by the CIT(A).

What were the issues?

Whether the re-assessment proceedings were vitiated due to non-furnishing of relevant documents and denial of cross-examination. Whether the addition of unexplained investment was made on proper evidence and due process.

Which sections of the Income-tax Act were involved?

Section 147,Section 144B,Section 69,Section 115BBE,Section 148A,Section 148,Section 143(2),Section 142(1)

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, SURAT BENCH, SURAT

Before: MS. SUCHITRA KAMBLE & SHRI B.M. BIYANI

For Appellant: Shri Yash kapadia, AR
For Respondent: Shri Ashish Kumar, Sr. DR
Hearing: 08.06.2026Pronounced: 07.08.2026

Per B.M. Biyani, A.M.:

Feeling aggrieved by the order of first appeal dated 16.04.2025 passed by learned Commissioner of Income-Tax (Appeals)-NFAC, Delhi [“Ld. CIT(A)”], which in turn arises out of the assessment-order dated 23.03.2024 passed by learned Assessment Unit of Income-tax Department [“Ld. AO”] u/s 147 r.w.s. 144B of Income-tax Act, 1961 [“the Act”] for Assessment-Year [“AY”] 2019-20, the assessee has filed this appeal on following grounds: Rachit Pramod Poddar “1. On the facts and circumstances of the case as well as the law on subject, the Hon'ble CIT(A) has erred in not providing with doc

The order continues below.

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