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

ITA 309/AHD/2026Status: DisposedITAT Chandigarh06 October 2026AY 2019-206 pages
AI SummaryRemanded

What did the Tribunal hold?

The Tribunal held that the interests of justice would be best 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 due opportunity to the assessee. The assessee was instructed to submit all relevant materials and supporting documents before the Ld. CIT(A) and to comply with notices without seeking unnecessary adjournments. The Tribunal did not decide the merits of the additions made by the AO or the grounds raised by the assessee, as the primary issue was the procedural fairness of the appellate proceedings before the CIT(A).

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 of a cash investment of Rs. 16,00,000 for a property purchase. 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 dismiss the appeal and confirm the addition.

What were the issues?

1. Whether, on the facts and in the circumstances of the case, the Ld. Commissioner of Income Tax (Appeals)-NFAC failed to dispose of the grounds of appeal supported by documentary evidence filed with Form No. 35 (question of fact and law, relying on principles of natural justice and proper adjudication). 2. Whether, on the facts and in the circumstances of the case, the Ld. Commissioner of Income Tax (Appeals)-NFAC erred in law by violating Section 250(6) of the Act and jurisdictional verdicts of the Hon'ble ITAT (Ahmedabad) (question of law, relying on Section 250(6) and ITAT precedents). 3. Whether, on the facts and in the circumstances of the case, the Ld. Commissioner of Income Tax (Appeals)-NFAC passed the order under Section 250 in a mechanical manner, without considering the facts and evidence available on the e-filing portal regarding the impugned additions (question of fact and law, relying on Section 250 and principles of fair adjudication). 4. Whether, on the facts and in the circumstances of the case, the Ld. Commissioner of Income Tax (Appeals)-NFAC erred by not addressing the issues raised in the Statement of Facts and by dealing with the illegality of proceedings under Section 147 of the Act (question of fact and law, relying on Section 147 and principles of due process). Assessee's contentions: The Ld. CIT(A) failed to dispose of grounds with supporting evidence, violated Section 250(6) and ITAT verdicts, passed a mechanical order without considering evidence, and failed to address issues and the legality of Section 147 proceedings. Revenue's contentions: The judgment records no specific contentions from the Revenue, but it notes the CIT(A) dismissed the appeal due to the assessee's non-participation and failure to provide evidence.

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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