LAXMI DHARAMSOTH,MANCHYA THANDA vs. ITO., WARD-1, WARANGAL

ITA 1249/HYD/2025Status: DisposedITAT Hyderabad19 December 2025AY 2017-18Bench: us: "1. The Assessing Officer (AO) is erred in reopening the assessment for the verification of information received by him. As it appears Assessment Order u/s.147 read with 144 of first para, said the unsecured loan of Rs.2,56,37,956/- is treated as income. By comparing the unsecured loan amount mentioned as on 31-03-2018 with Election Affidavit filed by the Husband of the Appellant (Dharamsoth Redya Naik) in November 2018 unsecured loan of Rs.2,56,37,956/-, with that of ITR figures of 31-1 pages
AI SummaryDismissed

What did the Tribunal hold?

The Tribunal upheld the CIT(A)'s decision to dismiss the appeal on the grounds of limitation. The assessee failed to provide a plausible explanation for the inordinate delay of 517 days in filing the appeal before the CIT(A).

What were the facts?

The Assessing Officer (AO) reopened the assessment for AY 2017-18 based on information from the Directorate of Systems regarding unsecured loans. The assessee disclosed a loan of Rs. 1,85,50,000/- in her return, but an Election Affidavit filed by her spouse showed Rs. 2,56,37,956/-. The AO treated the difference as escaped income due to unsubstantiated creditworthiness.

What were the issues?

Whether the appeal filed by the assessee was rightly dismissed by the CIT(A) on the grounds of limitation due to the inordinate delay in filing.

Which sections of the Income-tax Act were involved?

Section 147,Section 144,Section 144B,Section 148,Section 142(1),Section 270A,Section 272A(1)(d),Section 249(3)

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, Hyderabad ‘A’ Bench, Hyderabad

For Appellant: Shri S. Arun Kumar, Sr. AR

PER RAVISH SOOD, JM:

The present appeal filed by the assessee is directed against the order passed by the CIT(Appeals), National Faceless Appeal Centre, Delhi dated 27/05/2025, which in turn arises from the order passed by the Assessing Officer (for short, “AO”) under Section 147 r.w.s. 144

2 Laxmi Dharamsoth vs ITO r.w.s 144B of the Income Tax Act, 1961 (for short, “Act”) dated 29/03/2022, for the Assessment Year 2017-18. The assessee has assailed the impugned order of

The order continues below.

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