RAJESH KUMAR PAL,GANPURA vs. ITO, RANCHI

ITA 137/RAN/2026Status: DisposedITAT Ranchi24 June 2026AY 2018-197 pages
AI SummaryRemanded

What did the Tribunal hold?

The Tribunal restored the matter to the Assessing Officer, directing that the assessee be given an adequate opportunity to present their case and substantiate their income. The Tribunal noted the assessee's claim that the cash transactions were part of their business as a Banking Correspondent Agent.

What were the facts?

The assessee, a non-filer, was subjected to reassessment under Section 147 based on information about significant cash transactions. The Assessing Officer made additions based on these transactions, and the CIT(A) dismissed the assessee's appeal, citing a defect in the appeal form.

What were the issues?

Whether the lower authorities provided a reasonable opportunity of being heard to the assessee and whether the cash transactions represented the assessee's unexplained income or business-related remittances.

Which sections of the Income-tax Act were involved?

Section 147,Section 148A,Section 144,Section 69A

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, RANCHI BENCH, RANCHI

Before: SHRI PRADIP KUMAR CHOUBEY & SHRI RATNESH NANDAN SAHAY

For Appellant: Shri Raj Himmatsinghka, A.R
For Respondent: Shri Shubham Agarwal, Sr.DR
Hearing: 03/06/2026Pronounced: 24/06/2026

PER: RATNESH NANDAN SAHAY, A.M.

1.

This appeal by the assessee is directed against the order of the Addl/JCIT(A)- 1, Gurugram [in short, the ld. CIT(A)] dated 12/01/2026 for the Assessment Year (AY) 2018-19. The assessee has mainly challenged the action of the lower authorities that they had decided the appeal of the assessee without affording reasonable and fair opportunity of being heard.

2.

Facts of the case in brief are that the assessee is a non-filer of return of income. Subsequently, the case was reopened under Section 147 of the Income Tax Act, 1961 (in short, the Act) for the assessment on the basis of the informat

The order continues below.

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