AJAYKUMAR MAHADEVBHAI PATEL,VADODARA vs. THE ITO, WARD-1(2)(1) PREVIOUSLY WARD-1(2)(4), VADODARA

(Assessment Year:2017-18 Ajaykumar Mahadevbhai Patel, The Income Tax Officer, Vs. B-198, Shrenik Park, Ward 1(2)(1), Productivity Road, (Previously Ward-1(2)(4), Akota, Vadodara-390020. Vadodara.) [PAN :AEPPP2801 M] (Appellant) .. (Respondent) Appellant by : Shri PB Parmar, AR Respondent by: Shri Prateek Sharma, CIT. DR Date of Hearing 05.08.2025 Date of Pronouncement 25.08.2025 O R D E R PER DR. B.R.R. KUMAR, VICE-PRESIDENT:-

This appeal is filed by the Assessee against the appellate order dated 21.04.2025 passed by the Commissioner of Income Tax (Appeals) /National Faceless Appeal Centre, Delhi, relating to the Assessment Year 2017-18. 2. The assessee has raised the following grounds of appeal:

1. The Ld.CIT(A) has erred, both in law and on facts, in confirming the addition of Rs.27,07,000/- under section 69A of the Act in respect of alleged unexplained cash deposits in the bank account.

2. Both, AO & CIT(A), have erred in passing the impugned orders without properly appreciating facts of the case, submissions of the assessee and documentary evidences available on record in the correct perspective. Such an act is in gross violation of the principles of natural justice and hence, the impugned order deserves to be quashed.

3. The Ld.CIT(A) has erred in law and on facts of the case in confirming levy of interest u/s.234A/B/C/D of the Act.

Ajaykumar M Patel Vs. ITO Asst. Year : 2017-18 - 2– 4. The Ld.CIT(A) has erred in law and on facts of the case in confirming initiation of penalty proceedings under section271AAC(1) of the Act. 5. The appellant craves leave to add, amend, alter, edit delete, modify or change all or any of the grounds of appeal at the time of or before the hearing of the appeal.

3. The assessee filed his return of income on 22.07.2017 declaring total income of ₹2,86,290/-. The case was selected for complete scrutiny under CASS on account of high cash receipts and abnormal increase in cash deposits during the year, including during the demonetisation period. During the assessment proceedings, the assessee explained that the cash deposits were sourced from a gift of ₹47,00,000/- received from her brother, an NRI, comprising ₹26,00,000/- in cash and ₹21,00,000/- through cheques. Documentary evidences such as notarised gift deed, donor’s passport, donor’s bank statement, and assessee’s bank statement were furnished. The Assessing Officer, however, disbelieved the cash gift during demonetisation period and made an addition of ₹27,07,000/- u/s 69A of the Act. Aggrieved by the assessment order, the assessee filed appeal before the Ld. CIT(A) who confirmed the addition made by the Assessing Officer.

4. Aggrieved by the order of the Ld. CIT(A), the assessee is now in appeal before the Tribunal.

The order is pronounced in the open Court on 25.08.2025.

Sd/- Sd/- (SIDDHARTHA NAUTIYAL) (DR. B.R.R. KUMAR) JUDICIAL MEMBER VICE-PRESIDENT (True Copy) Ahmedabad; Dated 25.08.2025 MV आदेश की �ितिलिप अ�ेिषत/Copy of the Order forwarded to : 1. अपीलाथ� / The Appellant 2. ��थ� / The Respondent. 3. संबंिधत आयकर आयु� / Concerned CIT 4. आयकर आयु�(अपील) / The CIT(A)- 5. िवभागीय �ितिनिध, आयकर अपीलीय अिधकरण, अहमदाबाद / DR, ITAT, Ahmedabad 6. गाड� फाईल / Guard file. आदेशानुसार/ BY ORDER, True Copy