TANVEER AHMED SIDDIQUI,BANGALORE vs. INCOME TAX OFFICER, WARD-3(1)(3), BANGALORE

ITA 802/BANG/2026Status: DisposedITAT Bangalore29 September 2026AY 2016-20177 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that the addition of ₹75,42,374 made by the Assessing Officer was unjustified. The Tribunal examined the sale deed, which indicated that the assessee and his wife jointly purchased the property for ₹7,075,000 on 1 August 2015. The payment was made through the assessee's Federal Bank accounts. The assessee's balance sheet correctly reflected his 50% share of ₹3,771,187 as a fixed asset. The Tribunal noted that the AO was aware of the assessee declaring only his 50% share but still added the entire value. The NFAC confirmed the addition despite the assessee producing bank accounts and the sale deed. The Tribunal found that the consideration was paid from the assessee's bank accounts through his proprietary concern and that his share was reflected as a fixed asset, with the balance debited to his wife's account. Therefore, the addition could not be sustained in the assessee's hands. The Tribunal directed the AO to verify the entries in the assessee's Federal Bank statements and, if satisfied, to delete the addition.

What were the facts?

The assessee, Tanveer Ahmed Siddiqui, is an individual who did not file an initial return of income for Assessment Year 2016-17. Information received indicated taxable income from cash deposits and withdrawals, and property purchase. A notice under Section 148 was issued, and the assessee filed a nil return. Subsequently, the Assessing Officer (AO) issued notices under Sections 143(2) and 142(1). The assessee stated his income was from a roofing-sheet business and explained cash transactions and property purchase. The AO, however, added the entire consideration of ₹75,42,374 for a jointly purchased property under Section 69, as the assessee had declared only his 50% share. The National Faceless Appeal Centre (NFAC), Delhi, dismissed the assessee's appeal against the reassessment order passed by the AO under Section 147 read with Section 144B.

What were the issues?

1. Whether the addition of ₹75,42,374 made by the Assessing Officer is liable to be deleted, considering the assessee declared only his 50% share in the property and the payment was made through bank channels out of business funds, as per Section 69 of the Income-tax Act, 1961. Assessee's contentions: The assessee argued that the property was jointly purchased with his wife for ₹75,42,374, and he had declared his 50% share of ₹37,71,187 as a fixed asset. The payments were made through bank channels from his business accounts (Karnataka Roofing). Copies of the sale deed, balance sheet, and bank statements were provided as evidence. Revenue's contentions: The revenue, through the Assessing Officer and supported by the NFAC, contended that the entire consideration for the property was unexplained in the assessee's hands, leading to the addition under Section 69. The NFAC confirmed the addition due to alleged lack of adequate documentary evidence.

Which sections of the Income-tax Act were involved?

Section 147,Section 144B,Section 148,Section 143(2),Section 142(1),Section 69

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, BANGALORE BENCHES, BANGALORE

Before: SHRI PRASHANT MAHARISHI & SHRI KESHAV DUBEY

PER SHRI PRASHANT MAHARISHI, VICE PRESIDENT

1.

This appeal by the assessee challenges the appellate order dated 10 December 2025 passed by the National Faceless Appeal Centre (NFAC), Delhi, for assessment year 2016–17. By that order, the NFAC dismissed the assessee's appeal against the reassessment order dated 9 March 2024, passed by the ITA 802/BANG/2026 TANVEER AHMED SIDDIQUI

Assessment U

The order continues below.

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