KAJAL BATRA,DELHI vs. ACIT,CIRCLE-52(1), DELHI

ITA 2419/DEL/2025Status: DisposedITAT Delhi30 October 2025AY 2017-18Bench: SHRI VIJAY PAL RAO, HON’BLE (Vice President), SHRI AVDHESH KUMAR MISHRA (Accountant Member)15 pages
AI SummaryDismissed

What did the Tribunal hold?

The Tribunal upheld the reopening of the assessment, finding that the AO had sufficient prima facie material to believe that income had escaped assessment. However, the Tribunal declined to comment on the merits of the additions, as the CIT(A) had remanded the matter back to the AO for fresh adjudication.

What were the facts?

The Assessing Officer (AO) initiated reassessment proceedings against the assessee for AY 2017-18, alleging undisclosed income due to substantial cash deposits in two bank accounts, one of which was not disclosed in the Income Tax Return (ITR). The assessee challenged the reopening and the additions made.

What were the issues?

Whether the reopening of assessment under Section 147 was valid and whether the additions made on account of unexplained bank deposits were justified.

Which sections of the Income-tax Act were involved?

Section 147,Section 148,Section 151,Section 69A,Section 68

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Income Tax Appellate Tribunal, DELHI BENCH ‘A’: NEW DELHI

Before: SHRI VIJAY PAL RAO, HON’BLE & SHRI AVDHESH KUMAR MISHRA

Hearing: 30/09/2025Pronounced: 30/10/2025

PER AVDHESH KUMAR MISHRA, AM

The appeal for the Assessment Year (‘AY’) 2017-18 filed by the assessee is directed against the order dated 11.02.2025 passed by the Commissioner of Income Tax (Appeals), NFAC, Delhi [‘CIT(A)’].

2.

The assessee has raised following grounds of appeal: - “1. CIT(A) has erred in law and on facts in upholding the order u/s 147 r.w.s. 144 for the A.Y. 2017-18 despite the said order being beyond juri iction wrong and bad in law and on PAN No. AGQPB4318Q surrendered by the assessee appellant.

2.

The appellant contends that reasons recorded has no nexus with the additions made by the AO in the impugned order u/s 147 of the Ac

The order continues below.

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