Aravindan Rengasamy Vs ACIT (ITAT Chennai)
The appeal before the Income Tax Appellate Tribunal, Chennai, arose from a reassessment order passed under Sections 147 read with Sections 144 and 260 of the Income Tax Act for Assessment Year 2019–20. The assessee, an individual and a Non-Resident Indian employed in the UAE, had not filed a return of income for the relevant year. Based on Risk Management Strategy (RMS) information received by the Assessing Officer (AO), notices under Sections 148A(b) and 148 were issued, followed by a draft assessment treating multiple financial transactions as unexplained. The assessee challenged the draft order before the Madras High Court, which remitted the matter to the AO for a fresh order on merits. Thereafter, objections were filed before the Dispute Resolution Panel (DRP), along with additional evidence.
The DRP rejected the assessee’s objections, citing failure to substantiate claims regarding LIC receipts, sale and purchase of securities, and other reported transactions. The DRP also directed an additional large addition based on a “statement of reportable account” under Section 285BA(1), on the ground that no objection had been raised by the assessee. The AO passed the final assessment order in line with the DRP’s directions, making additions relating to sale of securities, purchase of securities, and reportable transactions.
