NEERAJ JAGDISHBHAI PARIKH,AHMEDABAD vs. ITO, WARD-1(3)1 AHMEDABAD, AHMEDABAD

ITA 2969/AHD/2026Status: DisposedITAT Ahmedabad23 October 2026AY 2015-165 pages
AI SummaryRemanded

What did the Tribunal hold?

The Tribunal noted that the assessee was afforded multiple opportunities by the CIT(A) to furnish details and explanations regarding the cash deposits under Section 69A of the Act, but remained non-compliant, sought adjournments, and failed to provide the requisite information. The assessee also failed to submit details to the AO. Before the ITAT, the assessee's counsel requested an opportunity to furnish all necessary details. The assessee offered to voluntarily pay ₹10,000/- to the Prime Minister's National Relief Fund. In the interest of justice, the Tribunal decided to remand the matter to the Assessing Officer for de-novo assessment. The assessee is directed to submit all relevant bank statements, submissions, and documents to the AO and comply with revenue notices without unnecessary adjournments. The appeal is allowed for statistical purposes.

What were the facts?

The assessee, Neeraj Jagdishbhai Parikh, is an individual who did not file a return of income for Assessment Year 2015-2016. The Assessing Officer (AO) received information about cash deposits totaling ₹1,42,51,400/- in the assessee's bank account. A notice under Section 148 was issued on March 27, 2021. During reassessment, the AO issued notices regarding these deposits, but the assessee did not respond. Consequently, an ex-parte assessment order under Section 144 was passed on March 27, 2022, making additions for salary income, business income, long-term capital gains (LTCG), and cash deposits, totaling ₹3,38,85,317/-. The assessee appealed to the Commissioner of Income-Tax (Appeals) [CIT(A)], who also issued notices. The assessee remained non-compliant, failed to provide documents, and the CIT(A) upheld the AO's additions, dismissing the appeal. The assessee then filed an appeal before the Income Tax Appellate Tribunal (ITAT).

What were the issues?

1. Whether the additions aggregating to ₹3,38,85,317/- made by the Assessing Officer and upheld by the CIT(A) are illegal, unlawful, and against the principles of natural justice, particularly concerning the non-compliance with notices? Assessee's Contention: The assessee argued that there was a sufficient cause for non-compliance with notices issued by the AO and CIT(A). The assessee also contended that the additions upheld by the CIT(A) ought not to have been made. Revenue's Contention: The revenue, through the Assessing Officer and CIT(A), proceeded ex-parte due to the assessee's non-compliance and failure to provide explanations or substantiating documents for the cash deposits and other income sources. The revenue's arguments are implicit in the orders passed by the lower authorities upholding the additions based on available material and the assessee's non-cooperation.

Which sections of the Income-tax Act were involved?

Section 250,Section 148,Section 144,Section 69A

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, “C” BENCH, AHMEDABAD

For Appellant: Shri Samir Vora, AR
For Respondent: Shri Kalpesh Rupavatia, Sr. DR
Hearing: 22.10.2026Pronounced: 23.10.2026

PER DR. B.R.R. KUMAR, VICE-PRESIDENT:

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This appeal has been filed by the assessee against the order dated 30.06.2026 passed by the Commissioner of Income-Tax (Appeals)/National Faceless Appeal Centre, 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 2015- 2016. ITA No.2969/AHD/2026, AY-2015-16 Neeraj J Parikh - 2–

2.

The Assessee has raised the following grounds of Appeal:-

1.

1 The order passed by U/s.250 passed on 30.06.206 for A.Y. 2015-16 by NFAC, [CIT(A)], Delhi (for short CIT(A)" upholding the additions aggregating to RS,3,38,85,317/ made

The order continues below.

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