HINABEN BABULAL PIPALIYA,RAJKOT vs. ITO WARD 1(1)(1), RAJKOT, RAJKOT

ITA 292/RJT/2026Status: DisposedITAT Rajkot25 September 2026AY 2020-215 pages
AI SummaryRemanded

What did the Tribunal hold?

The Tribunal held that the assessee should be provided with the seized documents pertaining to her and an opportunity for cross-examination. The matter was set aside and remitted back to the CIT(A) for fresh adjudication.

What were the facts?

During a search and survey action on real estate builders, incriminating documents were seized. The assessee claimed that she was not provided with the seized material and an opportunity for cross-examination by the lower authorities.

What were the issues?

Whether the assessee was denied natural justice by not being provided with seized documents and cross-examination opportunities. Whether the assessment proceedings against a third party were valid without establishing the relevance of seized documents to the assessee.

Which sections of the Income-tax Act were involved?

Section 147,Section 250,Section 132,Section 133A

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, “SMC”

Before: Dr. Arjun Lal Saini

For Appellant: Shri Fenil H. Mehta, Ld. AR
For Respondent: Shri Shishir Kumar, Ld. Sr. DR
Hearing: 30/07/2026Pronounced: 25/09/2026

Per, Dr. Arjun Lal Saini, AM:

Captioned two appeals filed by the assessee, pertaining to assessment years (AY) 2019-20 & 2020-21, are directed against the separate orders under section 250 of the Income-tax Act, 1961 (hereinafter referred to as ‘the Act’) passed by the National Faceless Appeal Centre (NAC) Delhi/Commissioner of Income-tax (Appeals) [in short ‘NFAC/Ld.CIT(A)’], dated 22.12.2025, which in turn arise out of separate assessment orders passed by the Assessing Officer u/s 147 of the Act.

ITA No. 292 & 294/Rjt/2026 H

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 →