JITESH KANTILAL JARIWALA,SURAT vs. ITO, WARD-1(2)(2), SURAT

ITA 1018/SRT/2024Status: DisposedITAT Surat27 July 2026AY 2014-1518 pages
AI SummaryPartly Allowed

What did the Tribunal hold?

The Tribunal restored the issue of the mandatory notice under Section 143(2) to the CIT(A) for adjudication. It also restored the issue of merits to the CIT(A) for readjudication after seeking a remand report from the AO.

What were the facts?

The assessee failed to disclose a bank account, leading to reopening of assessment under Section 147. The Assessing Officer added the entire credit entries in the undisclosed account as income under Section 69A. The CIT(A) confirmed the addition.

What were the issues?

Whether the assessment framed under Section 147 is valid without issuing a mandatory notice under Section 143(2). Whether the addition made under Section 69A for unexplained bank deposits is justified.

Which sections of the Income-tax Act were involved?

Section 69A,Section 147,Section 148,Section 143(2)

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, SURAT BENCH, SURAT

Before: Shri T. R. Senthil Kumar & Shri Ratnesh Nandan Sahay

For Appellant: Shri V I Rudalal, A.R. with Shri Rushi Parekh, C.A
For Respondent: Ms. Neerja Sharma, Sr. DR
Hearing: 07/05/2026Pronounced: 27/07/2026

PER: BENCH

1.

These are the appeals filed by the assessee against the separate orders of the National Faceless Appeal Centre (NFAC), Delhi [In short, ‘the ld. CIT(A)’] dated 01/07/2024 and 02/07/2024 for the assessment year (AY) 2010-11 to 2015-16 respectively. All these appeals have common facts and grounds, therefore, with the consent of parties, all appeals were clubbed and heard together and being decided by this common order.

2.

Firstly, we found from perusal of the record that there are delay in filing of all these appeals before this Tribunal, for which, the assessee has filed a common condonation petition

The order continues below.

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