VALJI HARJI HIRANI,BHUJ vs. ITO.(INT.TXN), GANDHIDHAM
In the result, the appeal of the assessee is allowed
ITA 119/RJT/2024[2018-19]Status: DisposedITAT Rajkot03 Nov 2025AY 2018-19
Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./Ita No.119/Rjt/2024 ("नधा"रण वष" / Assessment Year: (2018-19) Valji Harji Hirani Vs. Ito, (Int. Txn) Meghpar, Nr. Dena Bank, Gandhidham (Gujarat) – 370201 Bhuj (Gujarat) - 370430 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Agjph6338K (Appellant) (Respondent) Appellant By : Shri Samir Bhuptani, Ld. Ar Respondent By : Smt. Pallavi, Ld. Cit(Dr) : 05/08/2025 Date Of Hearing Date Of Pronouncement : 03/11/2025 आदेश / O R D E R Per, Dinesh Mohan Sinha, Jm: Captioned Appeal Filed By The Assessee, Pertaining To Assessment Year (Ay)-2018-19, Is Directed Against The Order Passed By The Dispute Resolution Panel(Drp-2), Vide Order Dated 29.12.2023, Which In Turn Assessment Order Passed By Income Tax Department / Assessing Officer Under Section 144C(5) Of The Income Tax Act, 1961 (In Short “The Act”), Vide Order Dated 18.01.2024. (Ita 2. Grounds Of Appeal Raised By The Assessee, Are As Follows: 1. The Learned Drp Panel Has Erroneously Applied Section 69 By Focusing On The Conditions Outlined In Section 69 Without Duly Considering The Applicant'S Submission Regarding The Source Of The Investment. It Is Emphasized That The Nre Fdrs In Question Are From Previous Years & Have Been Made From After Tax Income Earned Abroad, As Clearly Stated In The Submission. The Panel Has Failed To Acknowledge The Satisfactory Explanation Provided By The Assessee Regarding The Source Of Acquisition Of The Investment. Shri Leuva Patel Kelavani Mandal
For Appellant: Shri Samir Bhuptani, Ld. ARFor Respondent: Smt. Pallavi, Ld. CIT(DR)
Section 115BSection 144CSection 144C(5)Section 148Section 69
144C(5) of the act dated 29.12.2023 by contending that 5.3.3. The panel notes that the assessee has purchased time deposit amounting to Rs. 1,05,06,635/-. During the proceeding before this panel, the assessee has failed to discharge the onus of explaining the fact that the renewed time deposits have been purchased from explained sources. The assessee
