RAZIA SULTANA,BHILAI vs. INCOME TAX OFFICER, WARD-2(3), SIWAN, SIWAN, BIHAR

ITA 219/PAT/2026Status: DisposedITAT Patna28 July 2026AY 2020-216 pages
AI SummaryDismissed

What did the Tribunal hold?

The Tribunal held that the reassessment proceedings were validly initiated and the approval for reassessment was obtained correctly. Therefore, the CIT(A)'s order remanding the matter to the AO was not flawed.

What were the facts?

The assessee failed to file an ITR and had significant cash deposits and withdrawals, as well as interest income and mutual fund purchases. The AO treated a large sum as unexplained income and added back accumulated interest. The CIT(A) remanded the matter to the AO.

What were the issues?

The primary issue was the validity of the reassessment proceedings and the approval obtained for issuing the notice under Section 148A. The assessee argued that the approval was not properly obtained.

Which sections of the Income-tax Act were involved?

Section 148,Section 148A,Section 149,Section 151,Section 69A,Section 115BBE

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, PATNA “DB” BENCH

Before: SHRI LAXMI PRASAD SAHU & SHRI YOGESH KUMAR U.S.

For Appellant: Shri Giridhar Dheliya, CA
For Respondent: Shri Ravi Kant Chowdhary, Sr. DR
Hearing: 21.07.2026Pronounced: 28.07.2026

PER YOGESH KUMAR U.S., JUDICIAL MEMBER:

This Appeal is filed by the Assessee against the order of the NFAC, Delhi (‘Ld. CIT(A)’ for short) dated 22.01.2026, passed u/s 250 of the Income Tax Act, 1961 (“the Act”, for short) for the Assessment Year 2020-21. 2. Brief facts of the case as mentioned in the order of the Ld. CIT(A) is as under: -

“After perusal of assessment order, it is seen that the assessee has made cash deposit amounting 10,05,000/- and cash withdrawal of Rs. 3,22,200/- from saving account no. 3677148877 maintained with Central Bank of India and cash deposit of Rs. 50,000/- and cash withdrawal of Rs. 70,000/- from saving account no. 3575400220

The order continues below.

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