IXEET RAMLAL PATEL,AHMEDABAD vs. ITO-WARD-4(2)(3), AHMEDABAD

ITA 309/AHD/2026Status: DisposedITAT Ahmedabad06 October 2026AY 2019-206 pages
AI SummaryRemanded

What did the Tribunal hold?

The Tribunal held that the interests of justice would be served by giving the assessee an opportunity to present their case before the Ld. CIT(A). Consequently, the impugned order of the CIT(A) was set aside, and the matter was restored to the file of the CIT(A) for de novo adjudication. The CIT(A) was directed to pass a fresh order after providing the assessee with due opportunity. The assessee was instructed to submit all relevant materials and supporting documents and to comply with notices without seeking unnecessary adjournments. The Tribunal did not decide on the merits of the additions made by the AO or the grounds raised by the assessee, as the case was remanded for fresh consideration.

What were the facts?

The assessee, Ixeet Ramlal Patel, filed an appeal against the order dated 28.11.2025 passed by the Ld. Commissioner of Income Tax (Appeals), National Faceless Appeal Centre (NFAC), Delhi, for Assessment Year 2019-20. The assessee had initially filed a return of income declaring Rs. 5,71,380/-. The case was reopened under Section 147 of the Income-tax Act, 1961, due to information about a cash investment of Rs. 16,00,000/-. The Assessing Officer (AO) completed the assessment under Section 147, making an addition of Rs. 16,00,000/- as unexplained money under Section 69A. The assessee appealed to the CIT(A) but failed to participate in the proceedings or submit any evidence, leading the CIT(A) to confirm the addition and dismiss the appeal.

What were the issues?

1. Whether, on the facts and in the circumstances of the case, the Ld. CIT(A)-NFAC failed to dispose of grounds of appeal supported by documentary evidence filed with Form No. 35, as argued by the assessee. 2. Whether, on the facts and in the circumstances of the case, the Ld. CIT(A)-NFAC erred in law by violating Section 250(6) of the Act and a jurisdictional verdict of the Hon'ble ITAT (Ahmedabad), as argued by the assessee. 3. Whether, on the facts and in the circumstances of the case, the Ld. CIT(A)-NFAC passed the order under Section 250 in a mechanical manner, without fully and properly considering the facts and evidence available on the e-filing portal regarding the impugned additions, as argued by the assessee. 4. Whether, on the facts and in the circumstances of the case, the Ld. CIT(A)-NFAC erred by not bringing on record the issues raised in the Statement of Facts and by dealing with the illegality of proceedings under Section 147 of the Act, as argued by the assessee. The revenue did not record any specific arguments in the judgment.

Which sections of the Income-tax Act were involved?

Section 250,Section 147,Section 148,Section 69A,Section 250(6)

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, AHMEDABAD BENCHES, AHMEDABAD

Before: SHRI NARENDRA PRASAD SINHA & SHRI SANJAY KUMAR

Pronounced: 06.10.2026

PER SANJAY KUMAR, JUDICIAL MEMBER:

- This appeal has been filed by the Assessee against the order dated 28.11.2025 passed by the Ld. Commissioner of Income Tax (Appeals), National Faceless Appeal Centre (NFAC), Delhi (hereinafter referred to as ‘Ld. CIT (A)’ in short), under Section 250 of the Income-tax Act, 1961 (hereinafter referred to as ‘the Act’ in short) for Assessment Year 2019-20. 2. The Ass

The order continues below.

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