VIJAY KUMAR RUNGTA,HARDOI vs. ITO-3(3), HARDOI, HARDOI

ITA 331/LKW/2025Status: DisposedITAT Lucknow02 June 2026AY 2011-126 pages
AI SummaryRemanded

What did the Tribunal hold?

The Tribunal held that neither the AO nor the CIT(A) specified the exact evidence required from the assessee and passed orders without providing a reasonable opportunity. Therefore, the issues were restored to the AO for a fresh assessment.

What were the facts?

The assessee deposited Rs. 48,00,000/- in cash into bank accounts between March 24-31, 2011. The Assessing Officer (AO) and CIT(A) disallowed Rs. 31,20,000/- as unexplained investment, accepting only Rs. 16,80,000/- as explained cash in hand.

What were the issues?

Whether the addition of Rs. 31,20,000/- as unexplained investment is justified without specifying the required evidence and providing a reasonable opportunity to the assessee.

Which sections of the Income-tax Act were involved?

Section 148,Section 147,Section 144B,Section 69,Section 143(3)

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, LUCKNOW BENCH ‘SMC’, LUCKNOW

Before: SHRI ANADEE NATH MISSHRA

For Appellant: Shri Parnav Pandey, CA

PER ANADEE NATH MISSHRA:A.M.

(A) This appeal has been filed by the assessee against the impugned appellate order of learned CIT(A) / NFAC, Delhi, dated 20.09.2023, for the AY 2011-12. The assessee has raised the following grounds of appeal: “That the basis of initiation of re-assessment proceeding by issue of notice u/s148 of the Income Tax Act, 1961, its continuation and culmination vide order u/s 147/144B of the Income Tax Act, 1961 dated 24-12-2018 is bad in law and liable to be cancelled. That the CIT (Appeals) erred on facts and in law in confirming the addition of Rs. 31,20,000/- u/s 69 of the Income Tax Act, 1961 as unexplained investment, wh

The order continues below.

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