Pradeep Kumar Narsaria Vs ITO (ITAT Ranchi)
Reopening Based on Wrong Bank Account Details Set Aside – Matter Remanded to AO
The Ranchi Bench of the Income Tax Appellate Tribunal dealt with an appeal by Shri Pradeep Kumar Narsaria for AY 2015-16, challenging reassessment proceedings initiated on the basis of alleged large cash deposits.
Key aspects of the decision are:
Erroneous Basis for Reopening:
The Assessing Officer (AO) reopened the assessment alleging cash deposits of ₹2.05 crore in a bank account. However, the Tribunal found that:
- The account number mentioned in the reasons pertained to the assessee’s SBI savings account,
- While the transactions relied upon actually belonged to a Corporation Bank current account, and
- The figure of ₹2.05 crore did not match any deposits in either account.
Mismatch of Accounts and Figures:
Evidence on record showed that the cash deposits in the Corporation Bank account were about ₹1.26 crore, and no cash deposits existed in the SBI savings account referred to in the reopening reasons. This factual mismatch cast serious doubt on the validity of the reassessment.
Ex-parte Proceedings Noted:
The Tribunal noted that the assessment as well as the first appellate order were passed ex-parte, without proper appreciation of facts and documents.
