RATABHAI RAMBHAI SODHIYA,GANDHIDHAM vs. ITO WARD 2 GDHAM, GANDHIDHAM

ITA 741/RJT/2026Status: DisposedITAT Rajkot25 August 2026AY 2017-183 pages
AI SummaryPartly Allowed

What did the Tribunal hold?

The Tribunal condoned the delay in filing the appeal and, following a precedent, directed the Assessing Officer to restrict the addition to 10% of the disputed amount (Rs. 17,600/-). The addition was to be taxed under normal provisions, not under section 115BBE.

What were the facts?

The assessee purchased a vehicle for Rs. 1,76,000/- through cash payment. The Assessing Officer initiated proceedings under section 147 and treated the payment as unexplained investment under section 69, adding it to the total income. The CIT(A) upheld the AO's order.

What were the issues?

Validity of notice under section 148 and whether the unexplained investment should be taxed under section 115BBE or normal provisions.

Which sections of the Income-tax Act were involved?

Section 147,Section 148,Section 142(1),Section 144,Section 69,Section 115BBE

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, Rajkot Bench, Rajkot

Before: Dr. Arjun Lal Saini & Shri Sonjoy Sarma

For Appellant: Shri Rajendra Singhal, Ld. AR
For Respondent: Shri Ganesh Iyer, Ld. Sr. DR
Hearing: 24/08/2026Pronounced: 25/08/2026

Per, Shri Sonjoy Sarma, JM: Captioned appeal filed by the assessee, pertaining to Assessment Year (AY) 2017-18, is directed against the order under section 250 of the Income-tax Act, 1961 [hereinafter referred to as ‘the Act’] passed by the National Faceless Appeal Centre [hereinafter referred to as ‘NFAC’], dated 18.08.2025, which in turn arises out of an order passed by assessing officer u/s. 147 r.w.s. 144 of the Act, dated 28.03.2022. 02. Brief facts of the

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 49,210 judgments and leading authorities on Section 147 →

Recent GST High Court judgments

Search GST case law →