RITU RAJESH GOHIL,JAMNAGAR, GUJARAT vs. ITO WARD 2(1), JAMNAGAR, JAMNAGAR, GUJARAT

ITA 109/RJT/2026Status: DisposedITAT Rajkot15 October 2026AY 2018-193 pages
AI SummaryPartly Allowed

What did the Tribunal hold?

The Tribunal noted the CIT(Appeals) observation that the assessee possessed two PANs (BGRPG0759A and AEAPG4798M). It was deemed necessary to verify whether the income and transactions forming the basis of the addition had been duly disclosed by the assessee in the returns filed under PAN AEAPG4798M. The Tribunal held that the relevant bank statements, income returns, and assessment records pertaining to both PANs required examination to ascertain the correct facts and prevent duplication of income assessment. Consequently, the Tribunal set aside the impugned order and restored the matter to the AO for fresh examination and adjudication. The AO was directed to verify returns under both PANs, examine bank records, and determine if the income was already disclosed, while ensuring the assessee was given a reasonable opportunity to be heard and to furnish supporting evidence. The appeal was allowed for statistical purposes.

What were the facts?

The assessee, Ritu Rajesh Gohil, is in appeal against an order of the National Faceless Appeal Centre (NFAC) for Assessment Year 2018-19. The NFAC order arose from an assessment order passed by the Assessing Officer (AO) under Section 147 read with Section 144 of the Income-tax Act, 1961. The AO reopened the assessment based on information about the assessee's transactions. Bank statements revealed cash deposits aggregating to Rs. 4,16,54,500/- and credits totaling Rs. 1,53,34,259/-. In the absence of assessee's compliance, the AO made an addition of Rs. 5,69,88,759/-. The assessee's appeal before the CIT(Appeals) was dismissed due to a delay of 354 days. The CIT(Appeals) also noted the assessee possessed two PANs and directed verification.

What were the issues?

1. Whether the addition of Rs. 5,69,88,759/- made by the Assessing Officer is sustainable in law, considering the assessee was allotted two PANs and had filed returns under one of them? Assessee's contentions: The assessee argued that she was allotted two PANs: BGRPG0759A (allotted before marriage) and AEAPG4798M (allotted subsequently). Income was disclosed under PAN AEAPG4798M, but the AO considered bank records related to the other PAN. The assessee sought verification to ascertain if the income and transactions were already disclosed. Revenue's contentions: The Ld. DR did not object to restoring the matter to the AO for verification and fresh adjudication after providing an opportunity of hearing to the assessee.

Which sections of the Income-tax Act were involved?

Section 147,Section 144,Section 148,Section 142(1),Section 133(6),Section 250

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, Rajkot Bench, Rajkot

Before: Dr. Arjun Lal Saini & Shri Sonjoy Sarma

For Appellant: Shri Chetan Agarwal, Ld. AR
For Respondent: Shri Ravinder Sindhu, Ld. CIT(DR)
Hearing: 14/10/2026Pronounced: 15/10/2026

Per, Shri Sonjoy Sarma, JM: Captioned appeal filed by the assessee, pertaining to Assessment Year (AY) 2018-19, is directed against the order under section 250 of the Income-tax Act, 1961 [hereinafter referred to as ‘the Act’] passed by the National Faceless Appeal Centre [hereinafter referred to as ‘NFAC’], dated 12.11.2025, which in turn arises out of an order passed by assessing officer u/s. 147 read with section 144 of the Act, dated 29.03.2024.

The order continues below.

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