MANISHKUMAR RAMLAKHAN AGRAWAL,AHMEDABAD vs. WARD 6(1)(1) AHMEDABAD, AHMEDABAD

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ITA 1738/AHD/2024Status: DisposedITAT Ahmedabad25 April 2025AY 2016-17Bench: Shri T.R. Senthil Kumar (Judicial Member), Shri Narendra Prasad Sinha (Accountant Member)1 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that the Assessing Officer (AO) failed to record independent reasons for reopening the assessment, relying on 'borrowed satisfaction' from an investigation wing report without verification. The reassessment notice was found to be invalid.

What were the facts?

The assessee, an individual and Executive Director, filed an original return of income for AY 2016-17. The AO reopened the assessment under Section 147 alleging suspicious transactions aggregating Rs. 57,50,682/- during FY 2015-16. The AO alleged these were from price rigging by Kushal Group, treating them as unexplained money.

What were the issues?

Whether the reassessment proceedings were initiated on valid grounds and based on independent satisfaction of the Assessing Officer, or on 'borrowed satisfaction'.

Which sections of the Income-tax Act were involved?

Section 147,Section 144B,Section 132,Section 68,Section 148,Section 10(38),Section 69A,Section 115BBE,Section 143(1),Section 143(3),Section 144,Section 50C

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Income Tax Appellate Tribunal, AHMEDABAD “D” BENCH

Before: Shri T.R. Senthil Kumar & Shri Narendra Prasad Sinha

आदेश क� ��त�ल�प अ�े�षत / Copy of Order Forwarded to:- 1. Assessee 2. Revenue 3. Concerned CIT A.Y. 2016-17 Page No 9 Manishkumar Ramlakhan Agrawal. vs. ITO

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