“unexplained investment”

Income-Tax Officer, Ward-4(2)(1), Ahmedabad vs. Late Khodaji Ranchhodji Thakor Legal Heir Narendakumar Khodaji Thakor, Ahmedabad

In the result, the appeal filed by the Revenue is, therefore, dismissed

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyalआयकर अपील सं /Ita No.948/Ahd/2025 िनधा"रण वष" /Assessment Year : 2017-18 The Ito Late Khodaji Ranchhodji Ward-4(2)(1) बनाम/ Thakor V/S. Ahmedabad – 380 015 Legal Heir Narendrakumar Khodaji Thakor Ahmedabad – 382 481 "थायी लेखा सं./Pan: Afwpt 1453 K (अपीलाथ"/ Appellant) ("" यथ"/ Respondent) Assessee By : Shri Chetan Agarwal, Ar Revenue By : Shri B.P. Srivastava, Sr.Dr सुनवाई की तारीख/Date Of Hearing : 18/09/2025 घोषणा की तारीख /Date Of Pronouncement: 06/11/2025 आदेश/O R D E R Per Siddhartha Nautiyal, Jm: The Present Appeal Has Been Preferred By The Revenue Against The Order Of The Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi [Hereinafter Referred To As ‘Cit(A)’] Dated 24/02/2025 Passed U/S.250 Of The Income Tax Act, 1961 (Hereinafter Referred To As ‘The Act’) For The Assessment Year (Ay) 2017-2018. 2. The Revenue Has Raised The Following Grounds Of Appeal:

account of unexplained money and Rs. 31,70,000/-on account of unexplained investment) on the ground that the assessee had expired before issue of Notice u/s. 142(1) of the Act. despite the fact that: ITO vs. Late Khodaji Ranchhodji Thakor Legal Heir Narendrakumar Khodaji Thakor Asst. Year ... Further, the AO made an addition of Rs. 31,70,000/- representing the assessee’s investment in immovable property, which was treated as unexplained investment under section 69 of the Act. The total income of the assessee was thus assessed at Rs. 1,73,54,690/-. The assessment was therefore

Jayeshbhai Gordhanbhai Patel, Anand vs. The ITO, Ward-1(3)(1), Petlad

In the result, the appeal of the assessee is allowed for statistical purposes, in the interest of justice

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyalआयकर अपील सं /Ita No.71/Ahd/2025 िनधा"रण वष" /Assessment Year : 2011-12 Jayeshbhai Gordhanbhai Patel The Ito बनाम/ Kishan Cowk Ward-1(3)(1) V/S. Piplav, Anand – 388 460 Petlad – 388 450 Gujarat "थायी लेखा सं./Pan: Bixpp 2069 Q (अपीलाथ"/ Appellant) ("" यथ"/ Respondent) Assessee By : Shri Darshan Belani, Ar Revenue By : Shri C. Dharani Nath, Sr.Dr सुनवाई की तारीख/Date Of Hearing : 15/09/2025 घोषणा की तारीख /Date Of Pronouncement: 06/11/2025 आदेश/O R D E R Per Siddhartha Nautiyal, Jm: The Present Appeal Has Been Preferred By The Assessee Against The Order Of The Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi [Hereinafter Referred To As ‘Cit(A)’] Dated 29/09/2022 Passed U/S.250 Of The Income Tax Act, 1961 (Hereinafter Referred To As ‘The Act’) For The Assessment Year (Ay) 2011-2012. 2. The Assessee Has Raised The Following Grounds Of Appeal: “1. The Hon’Ble Cit(A) Erred In Law & Facts Of The Case By Upholding The Addition Amounting To Rs.23.30,500/- Made As Unexplained Investments In Case Of The Appellant For Ay 2011-12. 2. The Appellant Reserves The Right To Add/Alter Or Amend Any Of The Ground Of Appeal.” Jayeshbhai Gordhanbhai Patel Vs. Ito Asst. Year : 2011-12

erred in law and facts of the case by upholding the addition amounting to Rs.23.30,500/- made as unexplained investments in case of the appellant for AY 2011-12. 2. The appellant reserves the right to add/alter or amend any of the ground of appeal.” Jayeshbhai Gordhanbhai Patel ... grounds, inter alia, that the assessment order was passed without granting proper opportunity of hearing, that the addition of Rs. 23,30,500/- as unexplained investment was unjustified, and that the amount represented proceeds from sale of agricultural land not chargeable to tax under section

Mohanbhai Becharbhai Chauhan, Ahmedabad vs. Income Tax Officer Ward 1(2)(3), Ahmedabad

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal

India bearing account no. 392902010055153. 2. Addition of Rs. 4,00,000/- u/s 69 of the Income Tax Act, 1961 on the basis of unexplained investment being the amount of fixed deposit made during the year under consideration: Mohanbhai Becharbhai Chauhan vs. ITO Asst.Year –2012-13 - 2– On facts ... ADDL/JCIT (A) by confirming the order passed by the Ld. AO, has grossly erred in making addition of Rs. 4,00,000/- unexplained investment being the amount of fixed deposit made during the year under consideration u/s 69 of the Income Tax Act, 1961. 3. Initiating penalty proceeding u/s 272A

Ratnadeep Infrastructure Private Limited, Ahmedabad vs. Income Tax Officer, Old Ward 3(1)(3), New Ward 3(1)(2), Ahmedabad

In the result, the appeal of the assessee is allowed

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal1. आयकर अपील सं /Ita No.1490/Ahd/2025, Asst.Year 2011-12 2. आयकर अपील सं /Ita No.1491/Ahd/2025, Asst.Year 2012-13 Ratnadeep Infrastructure The Income Tax Officer बनाम/ Private Limited Old Ward-3(1)(3) V/S. 126, 1St Floor New 3 (1) (2) Neelam Shopping Center Krishna Nagar Chowk Ahmedabad – 382 346 "थायी लेखा सं./Pan: Aaecr 5728 F (अपीलाथ"/ Appellant) ("" यथ"/ Respondent) Assessee By : Shri Chetan Agarwal, Ar Revenue By : Shri Abhijit, Sr.Dr सुनवाई की तारीख/Date Of Hearing : 16/09/2025 घोषणा की तारीख /Date Of Pronouncement: 06/11/2025 आदेश/O R D E R Per Siddhartha Nautiyal, Jm: The Present Appeals Have Been Preferred By The Assessee Against The Separate Orders Of The Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi [Hereinafter Referred To As ‘Cit(A)’] Of Even Date 01/07/2025 Passed U/S.250 Of The Income Tax Act, 1961 (Hereinafter Referred To As ‘The Act’) For The Assessment Years (Ays) 2011-2012 & 2012-13. 2. The Assessee Has Raised The Following Grounds Of Appeal In Ita No.1490/Ahd/2025 For Ay 2011-12:

paid Rs. 60,00,000/- in cash out of unaccounted income toward the purchase of the said property and accordingly added the same as unexplained investment under section 69 of the Act. Though the assessee requested for cross-examination of Shri Bharat Patel, the witness expressed inability to attend ... NFAC, Delhi, challenging both the reopening under section 147 of the Act and the addition of Rs. 60,00,000/- as unexplained investment. In its written submissions, the assessee contended that reopening was invalid as it was based solely on a third-party statement without any independent verification or application