IMRANBHAI PATEL,VADODARA vs. THE ITO, WARD-1(2)(1), VADODARA
IN THE INCOME TAX APPELLATE TRIBUNAL
AHMEDABAD “D” BENCH
Before: Shri Siddhartha Nautiyal, Judicial Member And Shri Makarand Vasant Mahadeokar, Accountant Member
Imranbhai Patel
Tandalja Sarpanch Faliyu
Vadodara-390012
PAN:AWUPP7142C
(Appellant)
Vs
The ITO,
Ward-1(2)(1),
Vadodara
(Respondent)
Assessee Represented: Shri M.K. Patel, Advocate,
Revenue Represented: Shri Amit Pratap Singh, Sr.D.R.
Date of hearing
: 24-09-2025
Date of pronouncement : 25-09-2025
आदेश/ORDER
PER : SIDDHARTHA NAUTIYAL, JUDICIAL MEMBER:-
This appeal is filed by the Assessee as against the appellate order dated 11.06.2024 passed by the Commissioner of Income Tax
(Appeals), National Faceless Appeal Centre, Delhi, (in short referred to as “CIT(A)”), arising out of the assessment order passed under section 147 of the Income Tax Act, 1961 (hereinafter referred to as ‘the Act’) relating to the Assessment Year 2018-19. ITA No: 1438/Ahd/2025
Assessment Year: 2018-19
I.T.A No. 1438/Ahd/2025 A.Y. 2018-19 Page No Imranbhai Patel. Ltd. vs. ITO
2
2. The assessee has raised the following Grounds of Appeal:
The Learned Commissioner of Income Tax (Appeals) erred in disregarding the order on account of non attendance without considering the Grounds of Appeal filed by the appellant.
The Learned Commissioner of Income Tax (Appeals) erred in holding that the appellant had sold property a sum of Rs.84,00,000/- despite the fact that on the Grounds of Appeal it was stated that these were only one property which was sold by the appellant.
The Learned Commissioner of Income Tax (Appeals) erred in holding that the appellant was guilty of latches or negligence and does not take appropriate steps to peruse the remedy for a period of 84 days for delay in filing the appeal.
The Learned Commissioner of Income Tax (Appeals) erred in confirming the addition of Rs.84,00,000/- made by the Learned Assessing Officer.
The appellant craves the right to add to or alter, amend, substitute, delete or modify all or any of the above grounds of appeal.
The brief facts of the case are that during the year under consideration, the assessee had sold two immovable properties on 21.12.2017 for a consideration of Rs. 42,00,000/- each, totalling to Rs. 84,00,000/-. The stamp valuation authority, however, determined the value of the said properties at Rs. 23,84,673/- each, aggregating to Rs. 47,69,346/-. The Assessing Officer issued several notices to the assessee, but no compliance was made by the assessee. Since the assessee failed to respond to the notices and did not file any explanation, the Assessing Officer passed assessment order under section 144 of the Act. The Assessing Officer observed that as per the information uploaded by the Sub-