HANIFBHAI ISABHAI JUNEJA,RAJKOT vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE - 2(1) RAJKOT, RAJKOT

ITA 11/RJT/2026Status: DisposedITAT Rajkot31 August 2026AY 2020-215 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that the assessment order was invalid because the mandatory notice under section 143(2) of the Income-tax Act was not issued after the assessee filed a return in response to a notice under section 148.

What were the facts?

During a search operation, unaccounted cash transactions involving the assessee and Qutone Group were found. The Assessing Officer added Rs. 10,00,000 as unexplained income. The assessee contended that the transactions were related to tile sales to a Dargah and lacked corroborative evidence.

What were the issues?

Whether the reassessment proceedings are valid without issuing a mandatory notice under section 143(2) after a return is filed under section 148.

Which sections of the Income-tax Act were involved?

Section 147,Section 148,Section 143(2),Section 143(3),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 D. M. Rindani, Ld. AR
For Respondent: Shri Ganesh Iyer, Ld. Sr. DR
Hearing: 13/08/2026Pronounced: 31/08/2026

Per, Shri Sonjoy Sarma, JM: Captioned appeal filed by the assessee, pertaining to Assessment Year (AY) 2020-21, 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 19.09.2025, which in turn arises out of an order passed by assessing officer u/s. 147 of the Act, dated 24.03.2025. 02. Brief facts of the c

The order continues below.

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