SUNNY TARUNKUMAR DOSHI,JETPUR vs. THE ITO, WARD-1(1)(1), AHMEDABAD

ITA 288/AHD/2021Status: DisposedITAT Ahmedabad14 February 2025AY 2014-15Bench: SMT. ANNAPURNA GUPTA (Accountant Member), Ms. SUCHITRA KAMBLE (Judicial Member)13 pages
AI SummaryDismissed

What did the Tribunal hold?

The Tribunal held that the reopening of the assessment was justified as the issue was not examined in the original assessment. On merits, the addition was confirmed as the assessee failed to provide evidence of cancellation of the sale deed or refund of stamp duty.

What were the facts?

The assessee purchased agricultural land jointly with another person for a significant sum, but this purchase was not reflected in his books of account. The Assessing Officer reopened the assessment, treating the value of the assessee's share as income from undisclosed sources under Section 56(2)(vii)(b).

What were the issues?

Whether the reopening of assessment under Section 147 was valid, and whether the addition made under Section 56(2)(vii)(b) for the purchase of agricultural land without adequate consideration was justified.

Which sections of the Income-tax Act were involved?

Section 147,Section 56(2)(vii)(b),Section 69A,Section 143(3),Section 234A,Section 234B,Section 234C,Section 234D,Section 271(1)(c)

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Income Tax Appellate Tribunal, AHMEDABAD “D” BENCH, AHMEDABAD

Before: SMT. ANNAPURNA GUPTA & Ms. SUCHITRA KAMBLE

For Appellant: Shri Mohit Balani, AR
For Respondent: Shri Ankit Jain, Sr. DR
Hearing: 24.01.2025Pronounced: 14.02.2025

PER SUCHITRA KAMBLE, JUDICIAL MEMBER:

This appeal is filed by the Assessee against order dated 28.10.2021, passed by the CIT(A), National Faceless Appeal Centre (NFAC), Delhi for the Assessment Year 2014-15. 2. The assessee has raised the following grounds of appeal :-

“1. Learned CIT(A) has erred in law and on the facts of the case in confirming the action of learned AO in assuming the juri iction u/s.147 of the Act.

2.

Learned CIT(A) has erred in law and on facts of the case in confirming the action of learned AO in making an addition of Rs.69,49,250/- u/s.56(2)(vii)(b) of the

The order continues below.

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