SHAILESHKUMAR DAHYABHAI PATEL,VADODARA, GUJARAT vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE 2(1)(2) (NOW DCIT CIRCLE 2(1)(1), VADODARA, GUJARAT, VADODARA, GUJARAT

ITA 2131/AHD/2025Status: DisposedITAT Ahmedabad26 February 2026AY 2017-1815 pages
AI SummaryPartly Allowed

What did the Tribunal hold?

The Tribunal allowed the appeal partly. It deleted the disallowance of interest paid to relatives at 18% as reasonable and deleted the addition for unexplained income related to service tax liability. However, it upheld the disallowance of interest on unexplained loans and the addition for unexplained expenditure.

What were the facts?

The assessee's return for AY 2017-18 was assessed, with additions for unexplained unsecured loans, unexplained expenditure, disallowed interest, and unexplained income. The CIT(A) confirmed these additions. The assessee appealed, primarily arguing a lack of opportunity to be heard and violations of natural justice.

What were the issues?

Whether the CIT(A) violated principles of natural justice by not providing adequate opportunity of hearing. Whether interest paid to relatives at 18% is excessive, and if additions for unexplained income and expenditure are justified.

Which sections of the Income-tax Act were involved?

Section 68,Section 69C,Section 69A,Section 40A(2)(b),Section 234A,Section 234B,Section 270A

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Income Tax Appellate Tribunal, “D” BENCH, AHMEDABAD

Before: SMT. ANNAPURNA GUPTA & SHRI SIDDHARTHA NAUTIYAL

For Appellant: Shri Milin Mehta & Shri Bhavin Marfatia, ARs
For Respondent: Shri Rameshwar P Meena, Sr. DR
Hearing: 28.01.2026

PER SIDDHARTHA NAUTIYAL - JUDICIAL MEMBER:

This appeal has been filed by the Assessee against the order passed by the Ld. Commissioner of Income Tax (Appeals), (in short “Ld. CIT(A)”), National Faceless Appeal Centre (in short “NFAC”), Delhi vide order dated 18.09.2025 passed for A.Y. 2017-18. 2. The assessee has raised the following grounds of appeal:

“Invalid Order

1.

The learned Commissioner of Income Tax (Appeals), National Faceless Appeal Centre, Delhi ["CIT(A)"] erred in fact and in law in passing the impugned order without provid

The order continues below.

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