UMESHKUMAR PRATAPRAI AWTANI,AHMEDABAD vs. THE ITO, WARD-1(1)(3), AHMEDABAD

ITA 1976/AHD/2025Status: DisposedITAT Ahmedabad27 February 2026AY 2019-20Bench: the CIT(A). The CIT(A) dismissed the appeal of the assessee.4 pages
AI SummaryDismissed

What did the Tribunal hold?

The Tribunal held that the assessee failed to provide corroborative evidence for the genuineness of the alleged loan transaction from Narayan and Company, including loan documents, interest payment, or intent to repay the interest-free loans. Since the assessee could not establish the genuineness or business purpose of the unsecured loans, the addition of Rs. 32,70,000/- as unexplained money u/s 69A was rightly confirmed by the CIT(A).

What were the facts?

The assessee filed a nil income tax return for AY 2019-20. Following a search on an accommodation entry provider, proceedings u/s 147/148 were initiated against the assessee. The AO added Rs. 32,70,000/- as unexplained money u/s 69A, alleging it was an accommodation entry from Narayan and Company, which the assessee claimed was a genuine loan.

What were the issues?

1. Whether the addition of Rs. 32,70,000/- as accommodation entry/unexplained money u/s 69A was rightly confirmed. 2. Whether the notice issued u/s 148 was valid.

Which sections of the Income-tax Act were involved?

Section 69A,Section 148,Section 139(4),Section 147

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, AHMEDABAD “SMC” BENCH

Before: Dr. BRR Kumar & Ms. Suchitra Kamble

For Appellant: Shri Maulik Kansara, A.R
For Respondent: Shri Veerbadram Vislavath, Sr. D.R

Per Suchitra Kamble, Judicial Member:

This is an appeal filed against the order dated 07-10-2025 passed by National Faceless Appeal Centre (NFAC), Delhi for assessment year 2019-20. 2. The grounds of appeal are as under:- “1. Whether, on facts and in circumstances of the case and in law, Ld. CIT(A) erred in confirming the addition of accommodation entry of Rs. 32,70,000/- as unexplained money u/s. 69A of the Act?

2.

Whether, on facts and in circumstances of the case and in law, Ld. AO erred in issuing notice u/s. 148 of the act? Further, appellant craves leave to add, amend, alter or withdraw all or any ground of appeal.” Umeshkumar Prataprai Awtani

The order continues below.

Read the full judgment

A free account opens 10 full judgments a month. Re-reading one you have already opened does not count again.

See plans and prices

The summary, the parties, the sections and the citations above are open to everyone and always will be. Only the text of the order and the PDF are metered.

More judgments on Section 69A

All 15,297 judgments and leading authorities on Section 69A →

Recent GST High Court judgments

Search GST case law →