PRAKASH RAMJIBHAI NANDA,VALSAD vs. ITO, WARD-7, VAPI

ITA 826/SRT/2024Status: DisposedITAT Surat25 August 2026AY 2014-154 pages
AI SummaryRemanded

What were the facts?

The assessee had two PANs and filed a return under one. The Assessing Officer reopened the case under Section 147 for undisclosed deposits in a bank account linked to the second PAN, which the assessee claimed was surrendered. The CIT(A) confirmed the addition.

What did the Tribunal hold?

The Tribunal found that factual aspects regarding the utilization of two PANs, the surrender of one, and the verification of bank deposits needed proper adjudication. Therefore, the matter was remanded back to the Assessing Officer for verification.

What were the issues?

Whether reassessment proceedings were validly initiated and if the addition made on account of bank deposits was justified, considering the assessee's claim of having two PANs and surrendering one.

Which sections of the Income-tax Act were involved?

Section 147,Section 148,Section 272B

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, SURAT BENCH, SURAT

For Appellant: Shri Hardik Vora, AR
For Respondent: Shri Ashish Pophare, CIT (DR)
Hearing: 18.06.2026Pronounced: 25.08.2026

PER : SUCHITRA KAMBLE, J M:

The appeal filed by the assessee is against the order passed by the Learned Commissioner of Income Tax (Appeals), National Faceless Appeal Centre (NFAC), Delhi [in short “CIT(A)”] dated 04.07.2024 for the Assessment Year (in short “AY”) 2014-15. 2. The assessee has raised the following grounds of appeal:

“1. On the facts and circumstances of the case as well as law on the subject, the learned CIT (Appeals) has erred in confirming reassessment proceedings u/s 147 of the IT Act, 1961. 2. On the facts and circumstances of the case as well as law on the subject, the learned CIT (Appeals) has erred in passing order without providing enough opportunities.

3.

On the facts and circumstances of the case as well as la

The order continues below.

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