HINABEN BABULAL PIPALIYA ,RAJKOT vs. ITO WARD 1, MORBI , MORBI

ITA 294/RJT/2026Status: DisposedITAT Rajkot25 September 2026AY 2019-205 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.

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