GHANSHYAM RAMCHANDRA KRIPLANI,AHMEDABAD vs. THE INCOME TAX OFFICER, INTL. TAXN. WARD-1, AHMEDABAD

ITA 566/AHD/2024Status: DisposedITAT Ahmedabad27 February 2025AY 2015-16Bench: SMT.ANNAPURNA GUPTA (Accountant Member), SHRI T.R. SENTHIL KUMAR (Judicial Member)1 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that the assessee had sufficiently demonstrated that the investment in FDs was sourced from his business in the UAE. The Tribunal also noted that an identical explanation for investment in immovable property was accepted by the AO.

What were the facts?

The assessee, a non-resident, invested Rs. 1 crore in fixed deposits. The Assessing Officer (AO) added this amount to the assessee's income as unexplained investment. The assessee claimed the funds were repatriated from his business in the UAE.

What were the issues?

Whether the source of Rs. 1 crore invested in fixed deposits by a non-resident assessee was sufficiently explained as business income from abroad.

Which sections of the Income-tax Act were involved?

Section 69,Section 147,Section 148A,Section 144C

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, “D” BENCH, AHMEDABAD

Before: SMT.ANNAPURNA GUPTA & SHRI T.R. SENTHIL KUMAR

For Appellant: Shri S.N. Divetia, AR and Shri Samir Vora, AR, Shri Prathvi Raj Meena, CIT-DR
Hearing: 08/01/2025Pronounced: 27/02/2025

आदेश आदेश आदेश

PER ANNAPURNA GUPTA, ACCOUNTANT MEMBER

The above appeal has been filed by the assessee against order passed by the Assessing Officer passed under section 147 read with section 144C(13) on 30.1.2024 in compliance of the directions of the DRP vide its order under section 144C(5) of the Income Tax Act, 1961 ("the Act" for short) pertaining to Assessment Year 2015-16. 2. The grounds raised by the assessee

The order continues below.

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