NASEER AHMED,YADGIR, KARNATAKA vs. ASSESSING OFFICER, WARD-24(3)(1), MUMBAI, MAHARASHTRA

ITA 9208/MUM/2025Status: DisposedITAT Mumbai02 April 2026AY 2016-1710 pages
AI SummaryDismissed

What were the facts?

The assessee challenged an order upholding additions made by the Assessing Officer (AO) for AY 2016-17. The AO initiated reassessment proceedings based on cash deposits in bank accounts, treating Rs. 57,84,722 as unexplained income under Section 69A. The assessee claimed the deposits were from agricultural income, dairy business, and past savings but failed to provide substantiating evidence.

What did the Tribunal hold?

The Tribunal held that the reopening of assessment under Section 147 was justified based on credible information like RMS data and AIR information. The Tribunal also sustained the addition under Section 69A as the assessee failed to discharge the burden of proof by providing adequate evidence for the claimed sources of income.

What were the issues?

Whether the reopening of assessment under Section 147 was valid and whether the addition of cash deposits as unexplained income under Section 69A was justified in the absence of substantiating evidence.

Which sections of the Income-tax Act were involved?

Section 147,Section 144,Section 144B,Section 148,Section 149,Section 69A,Section 115BBE,Section 2(1A),Section 234A,Section 234B,Section 234C,Section 282,Section 133(6),Section 142(1),Section 143(2),Section 148A

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, “B” BENCH MUMBAI

For Respondent: Shri Swapnil Choudhari (SR. DR)
Hearing: 10.03.2026Pronounced: 02.04.2026

PER SANDEEP GOSAIN, JM: The present appeal has been filed by the assessee challenging the impugned order dated 09.10.2025 passed u/s 250 of the Income Tax Act, 1961 (‘the Act’), by the National Faceless Appeal Centre, Delhi (NFAC) for the assessment year 2016-17. The following grounds are reproduced below:

2 “1. On facts and circumstances of the Appellants case, the impugned order of the lower authorities are opposed to law, equity, weight of evidence and probabilities.

2.

On facts and circumstances of the Appellants case, the learned assessing officer erred in assuming juri iction for making assessment under section 147 r.ws. 144 of IT Act 1961,

The order continues below.

Read the full judgment

A free account opens 10 full judgments a month. Re-reading one you have already opened does not count again.

Create a free accountSign in

See plans and prices

The summary, the parties, the sections and the citations above are open to everyone and always will be. Only the text of the order and the PDF are metered.

More judgments on Section 147

All 48,773 judgments and leading authorities on Section 147 →

Recent GST High Court judgments

Search GST case law →