MANISHKUMAR PRATAPSINH KATARA,ANAND vs. THE ITO WARD-1, ANAND

IN THE INCOME TAX APPELLATE TRIBUNAL “B” BENCH, AHMEDABAD BEFORE DR. B.R.R. KUMAR, VICE-PRESIDENT & SHRI RAHUL CHAUDHARY, JUDICIAL MEMBER ITA No.214/Ahd/2026 (Assessment Year: 2015-16) Manishkumar Pratapsinh Katara, Income Tax Officer, Vs. 151, Sai Palace Bunglow, Ward-1, Sardar Nagar Society, Anand. B/h Radha Swami Petrol Pump, Karamsad-388325.

[PAN :AHQPK2751 B] (Appellant) .. (Respondent) Appellant by : Shri Mehuk K Patel, Advocate Respondent by: Shri Abhijit, Sr. DR Date of Hearing 08.06.2026 Date of Pronouncement 12.06.2026 O R D E R PER DR. B.R.R. KUMAR, VICE-PRESIDENT:- Delay Condoned This appeal is filed by the Assessee against the appellate order dated 19.11.2025 passed by the Commissioner of Income Tax (Appeals)/National Faceless Appeal Centre, Delhi, relating to the Assessment Year 2015-16.

ITA No. 214/Ahd/2026 Asst. Year : 2015-16 - 2– 2. The Learned Commissioner of Income Tax (Appeals) erred in disregarding the Statement of Facts and Grounds of Appeal filed before him. 3. The Learned Commissioner of Income Tax (Appeals) erred in not giving proper opportunity of your appellant and erred in dismissing the appeal of the appellant for non attendance. 4. The Learned Commissioner of Income Tax (Appeals) erred in confirming the addition of Rs.34,80,000/- u/s 69A of the Act. 5. The Learned Commissioner of Income Tax (Appeals) erred in confirming the addition of Rs.57,29,200/- u/s 69 of the Act. 6. The Learned Commissioner of Income Tax (Appeals) erred in confirming the addition of Rs.60,000/- u/s 44AD of the Act. 7. The appellant craves the right to add to or alter, amend, substitute, delete or modify all or any of the above grounds of appeal. 3. On perusal of the records, it is observed that the assessee was afforded several opportunities of hearing on 29.07.2025, 10.09.2025, 24.09.2025 and 27.10.2025 to furnish details, clarifications and explanations to substantiate the source of unexplained cash deposits under section 69 of the Act. However, despite being granted multiple opportunities, the assessee remained non-compliant and failed to furnish the requisite details or explanations before the Ld. CIT(A). Consequently, the Ld. CIT(A), based on the material available on record, upheld the action of the Assessing Officer and dismissed the appeal of the assessee. We further observe that the assessee also failed to submit any details or supporting evidence to establish the source of unexplained cash deposits even before the Assessing Officer. It is found that 7 notices have been issued by the Assessing Officer and 4 notices have been issued by the Ld.CIT (A), which were found to be un- complied with. When pointed out about the wastage of resources of the

ITA No. 214/Ahd/2026 Asst. Year : 2015-16 - 3– Nation, it was submitted that an amount of Rs.5,000/- would be contributed by the assessee to the “Prime Minister’s National Relief Fund”. And the receipt of the shall be submitted before the Jurisdictional Assessing Officer, who shall take it on record. The Ld. Counsel for the assessee prayed that, given an opportunity, the assessee would furnish all the necessary details, clarifications and explanations before the revenue authorities.

Considering the totality of the facts and in the interest of justice, we deem it appropriate to remand the matter to the file of the Assessing Officer for conducting the assessment de novo. The assessee is directed to submit all relevant bank statements, documents and explanations before the Assessing Officer and to strictly comply with the notices issued by the revenue authorities without seeking any unnecessary adjournments.

The order is pronounced in the open Court on 12.06.2026.

Sd/- Sd/- (RAHUL CHAUDHARY) (DR. B.R.R. KUMAR) JUDICIAL MEMBER VICE-PRESIDENT (True Copy) (True Copy) Ahmedabad; Dated 12.06.2026 MV

ITA No. 214/Ahd/2026 Asst. Year : 2015-16 - 4– आदेश की �ितिलिप अ�ेिषत/Copy of the Order forwarded to : 1. अपीलाथ� / The Appellant 2. ��थ� / The Respondent. 3. संबंिधत आयकर आयु� / Concerned CIT 4. आयकर आयु�(अपील) / The CIT(A)- 5. िवभागीय �ितिनिध, आयकर अपीलीय अिधकरण, अहमदाबाद / DR, ITAT, Ahmedabad 6. गाड� फाईल / Guard file. आदेशानुसार/ BY ORDER, True Copy

सहायक पंजीकार (Dy./Asstt. Registrar) आयकर अपीलीय अिधकरण, अहमदाबाद / ITAT, Ahmedabad