MS TAPULAL AMARSINH THAKKAR AND CO.,VALSAD vs. ITO, WARD 4, VALSAD, VALSAD

- This appeal has been filed by the assessee against the order dated 26.01.2025 passed by the Ld. Commissioner of Income-Tax (Appeals), National Faceless Appeal Centre (NFAC), Delhi (hereinafter referred to as the “Ld. CIT(A)”), under Section 250 of the Income-tax Act, 1961 (hereinafter referred to as the “Act”) for Assessment Year 2018-19.

The assessee has raised following grounds :-

On perusal of the records, it is observed that the assessee was afforded five opportunities of hearing to furnish details, clarifications, and explanations with regard to the impugned cash withdrawals. However, despite being granted M/s Tapulal Amarsinh Thakkar and Co. Vs. ITO Asst. Year : 2018-19 - 2– multiple opportunities, the assessee failed to furnish the requisite details or explanations before the Ld. CIT(A). Consequently, the Ld. CIT(A), based on the material available on record, upheld the action of the Assessing Officer and dismissed the appeal of the assessee. We also find that the assessee remained non- compliant before the Assessing Officer and failed to furnish any documentary evidence in support of the impugned cash withdrawals. Before us, the Ld. Counsel for the assessee prayed that, given an opportunity, all necessary details, clarifications, and explanations would be furnished to the Revenue authorities. Hence, in the interest of justice, we set aside the order of the Ld. CIT(A) and restore the matter to the file of the Assessing Officer for de novo adjudication. The assessee shall submit all the relevant bank statement/submission/document before the Assessing Officer and comply with the notices issued by the revenue authorities without seeking any unnecessary adjournments.

In the result, the appeal of the assessee is allowed for statistical purposes. This order is pronounced in the open Court on 23.01.2026