PREMAL P PANDYA,DELHI vs. DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE 2(1)(1), AHMEDABAD

ITA 195/AHD/2026Status: DisposedITAT Ahmedabad14 May 2026AY 2022-2332 pages
AI SummaryDismissed

What were the facts?

The assessee received a reward of USD 2.18 million from the US Securities and Exchange Commission (SEC) for whistleblowing. The Assessing Officer treated this reward as taxable income under Section 56(2)(x) of the Income Tax Act, which was upheld by the CIT(A).

What did the Tribunal hold?

The Tribunal held that the reward received from the US SEC is taxable income. While Section 56(2)(x) might not be directly applicable, the reward is taxable under the residuary provision of Section 56(1) as 'Income from other sources'.

What were the issues?

Whether the reward received from a foreign securities regulator for whistleblowing is taxable in India, and if so, under which provision of the Income Tax Act.

Which sections of the Income-tax Act were involved?

Section 56(2)(x),Section 56(1),Section 10(17A),Section 234B,Section 234D

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, “B” BENCH, AHMEDABAD

Before: MS SUCHITRA KAMBLE & SHRI NARENDRA PRASAD SINHA

For Appellant: Shri S. N. Soparkar, Sr. Advocate
For Respondent: Shri R P Rastogi, CIT-DR
Hearing: 24.02.2026Pronounced: 14.05.2026

PER NARENDRA PRASAD SINHA, ACCOUNTANT MEMBER:

This appeal is filed by the assessee against the order of National Faceless Appeal Centre (NFAC), Delhi [hereinafter referred to as ‘CIT(A)’] dated 22.12.2025 for the Assessment Year (A.Y.) 2022-23 in the proceeding u/s 143(3) r.w.s. 144B of the Income Tax Act (hereinafter referred as “the Act”).

2.

The brief facts of the case are that the assessee had filed his return of income for A.Y. 2022-23 on 30.07.2022 declaring total income of Rs.33,190/-. The case was selected for scrutiny and a notice u/s. 143(2) of the Act was issued on 02.06.2023. The assessee is a resident individual Premal P P

The order continues below.

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