ITAT Restores ₹15 Crore Cash Addition: CIT(A) Failed to Seek Remand Report & Violated Rule 46A

ITO Vs Baldev Prasad Patel (ITAT Raipur)

CIT(A) Deleted ₹15.81 Cr Addition Based on Fresh Evidence Without Remand Report—Matter Remanded Back for Rule 46A Violation

Revenue challenged the NFAC order dated 07.08.2025 whereby the CIT(A)/NFAC deleted an addition of Rs.15,81,34,560/- made u/s 69A. Assessee had neither filed a return nor responded to notices u/s 148 & 142(1), due to which the AO completed reassessment u/s 147 r.w.s 144 r.w.s 144B based on huge cash deposits in a Punjab National Bank account.

CIT(A)/NFAC accepted fresh evide

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