HARSHAL JAGANNATH GAVATE,DHULE vs. THE INCOME TAX OFFICER, WARD 1, DHULE, DHULE

ITA 1082/PUN/2026Status: DisposedITAT Pune24 September 2026AY 2013-1423 pages
AI SummaryPartly Allowed

What did the Tribunal hold?

The Tribunal held that while the assessee failed to provide details of commission income, a reasonable percentage of the deposits should be considered as income. The addition was restricted to 4% of the total deposits.

What were the facts?

The assessee did not file an income tax return for AY 2013-14. Information indicated significant credits in a cooperative society bank account, leading to reassessment proceedings. The Assessing Officer made an addition of Rs. 1,48,07,595/- as unexplained money.

What were the issues?

The primary issues were the validity of the notice issued under Section 148 and the justification for the addition made under Section 69A for unexplained deposits in a cooperative society.

Which sections of the Income-tax Act were involved?

Section 148,Section 148A,Section 149,Section 69A,Section 147,Section 143(3),Section 153C

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, PUNE BENCH “A”, PUNE

Before: SHRI MANISH BORAD & SHRI VINAY BHAMORE

For Appellant: Shri Sanjeev Mutha (Virtual)
For Respondent: Shri Rajesh Haladkar
Hearing: 01.07.2026Pronounced: 24.09.2026

PER VINAY BHAMORE, JM: This appeal filed by the assessee is directed against the order dated 13.02.2026 passed by Ld. CIT(A)/NFAC for the assessment year 2013-14. 2. The appellant has raised the following grounds of appeal :- “1. On the basis of the facts and in the circumstances of the case, the Ld. CIT(A) is not justified in holding that the notice issued u/s. 148 in the instant case by the Juri ictional Assessing Officer is valid though the same is not issued through automated allocation, in accordance with risk management strategy formulated by the Board as referred to in section 148/144B of 2 the Act and as per Circular No. 18/2022/F No. 370142/16/ 2022 TPL (Part-1) dated 29/03/2022. 2.

The order continues below.

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