MAMTA SANJAY DAND,BULDHANA vs. THE INCOME-TAX OFFICER, WARD 1, KHAMGAON, BULDHANA

ITA 137/NAG/2025Status: DisposedITAT Nagpur07 April 2026AY 2014-157 pages
AI SummaryAllowed

What did the Tribunal hold?

The tribunal held that the second reopening of assessment was bad in law as it was based on a change of opinion and lacked tangible material. Furthermore, the addition of the entire bank deposits without considering the nature of transactions and without applying the peak credit principle was unsustainable.

What were the facts?

The assessee, an individual, did not file her return of income for AY 2014-15. A notice u/s 148 was issued, and a return was filed. Subsequently, a second notice u/s 148 was issued to verify bank credits, leading to an ex-parte reassessment order adding Rs. 8,36,02,744/- as unexplained under section 69A.

What were the issues?

Validity of second reopening under section 147/148; correctness of addition made under section 69A for unexplained bank deposits.

Which sections of the Income-tax Act were involved?

Section 147,Section 143(3),Section 144B,Section 148,Section 69A,Section 151,Section 250

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Income Tax Appellate Tribunal, NAGPUR BENCH :: NAGPUR

For Appellant: Shri Sanjeev Mutha, CA
For Respondent: Shri Pankaj Kumar, CIT-DR
Hearing: 23.02.2026Pronounced: 07.04.2026

PER KHETTRA MOHAN ROY, AM: This appeal filed by the assessee is directed against the order of Ld. Commissioner of Income Tax (Appeals)/NFAC, Delhi, dated 25/01/2025 passed under section 250 of the Income Tax Act, 1961 (for short, “Act”), which is arising out of assessment order passed u/s. 147 r.w.s. 144 r.w.s. 144B of the Act, dated 11.03.2022 for the Assessment Year 2014-15. ITA No. 137/NAG/20245 (Mamta Sanjay Dand)

2.

Brief facts of the case are that assessee is an individual and did not file her return of income for AY 2014. A notice u/s 148 was issued on 31.05.2018, pursuant to which return was filed on 12.12.2019 declaring income of Rs. 6,37,670/-, which was accepted u/s.147 r.w.s. 143(3) on 27.12.2019. Subsequently, anot

The order continues below.

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