RAJEEV KUMAR,PATNA vs. DCIT, CENTRAL CIRCLE-1, PATNA

ITA 388/PAT/2025Status: DisposedITAT Patna21 July 2026AY 2023-246 pages
AI SummaryPartly Allowed

What did the Tribunal hold?

The ITAT noted that the DVO's report was received beyond the stipulated period. Considering the assessee's concession for a 50% estimated disallowance on the amount confirmed by the CIT(A), the Tribunal confirmed 50% of that amount.

What were the facts?

A search operation revealed an unexplained investment in a residential building. The assessee declared a certain cost of construction, but the DVO's valuation was significantly higher. The CIT(A) confirmed 85% of the addition made by the AO.

What were the issues?

Whether the addition on account of unexplained investment in a building is justified, considering the DVO's valuation and the procedural timelines. The extent of disallowance to be confirmed on an estimated basis.

Which sections of the Income-tax Act were involved?

Section 69,Section 142A,Section 142(2A)

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, PATNA BENCH, PATNA

For Appellant: Shri Subhash Agarwal, AR
For Respondent: Shri Bharat Bhusan Garg, CIT-DR
Hearing: 02.07.2026Pronounced: 21.07.2026

PER LAXMI PRASAD SAHU, ACCOUNTANT MEMBER

These two appeals filed by the assessee against the separate orders passed u/s 250 of the Income Tax Act, 1961 (hereinafter referred to as “the Act”) by the Ld. Commissioner of Income Tax (Appeals), Patna-3, [hereinafter referred to as “the Ld. CIT(A)] dated 30.06.2025, DIN & order No. ITBA/APL/S/250/2025-26/1078011000(1) and ITBA/APL/S/250/2025-26/1078011393(1) for AYs 2022-23 and 2023- 24 respectively. Since the issues involved are similar in both the appeals and heard together and are being disposed off. For the sake of convenience, we a

The order continues below.

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