SHRI VISHNUBHAI RAMNIKBHAI TALVANIYA,AT VAGHGADH, DHRANGADHRA, SURENDRANAGAR vs. INCOME TAX OFFICER WARD 2 SURENDRANAGAR, SURENDRANAGAR

ITA 684/RJT/2025Status: DisposedITAT Rajkot31 August 2026AY 2018-198 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that the approval for reopening under Section 151 was mechanical and lacked application of mind. It also found no live nexus between the cash deposits and escaped income, especially as the accounts were jointly held and deposits could be linked to agricultural income.

What were the facts?

The Assessing Officer reopened the assessment of the assessee for AY 2018-19 based on information of cash deposits in bank accounts. The assessee failed to provide explanations, and the entire deposits were added to his income. The CIT(A) upheld the assessment.

What were the issues?

Whether the reopening of assessment under Section 147 was valid due to mechanical approval under Section 151 and lack of a live nexus between cash deposits and escaped income.

Which sections of the Income-tax Act were involved?

Section 147,Section 144,Section 271AAC(1),Section 151,Section 148,Section 69A,Section 142(1),Section 144B,Section 10(1)

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 Kalpesh Doshi, Ld. AR
For Respondent: Shri Ganesh Iyer, Ld. Sr. DR
Hearing: 19/08/2026Pronounced: 31/08/2026

Per, Shri Sonjoy Sarma, JM: Captioned these appeal ITA No. 662/Rjt/2025 for A.Y. 2018-19 is directed against the order of the Ld. CIT(A) dated 11.12.2024, arising out of the assessment framed under section 147 read with section 144 of the Income- tax Act, 1961 vide dated 09.03.2023. ITA No. 684/Rjt/2025 for A.Y. 2018-19 is directed against the order of the Ld. CIT(A) dated 23.12.2024, arising out of the penalty proceedings under section 271AAC(1) of the Act, vide order dated 01.09.2023 respectively. Since both the appeals hav

The order continues below.

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