Jatin Kumar Patel Vs ITO (ITAT Ahmedabad)
The appeal before the Income Tax Appellate Tribunal, Ahmedabad arose from an order dated 11.08.2025 passed by the National Faceless Appeal Centre (NFAC) for Assessment Year 2014-15. The assessee challenged the validity of the assessment order passed under Section 144 read with Section 263 of the Income-tax Act and the appellate order confirming the addition.
The case originated from information flagged under the Risk Management Strategy of the Central Board of Direct Taxes indicating large transactions in the assessee’s bank accounts during Financial Year 2013-14. Based on this information, the Assessing Officer issued notice under Section 148 on 27.07.2022 and initiated reassessment proceedings. During the proceedings, it was noted that aggregate credits of about ₹123.12 crore had appeared in the assessee’s bank accounts, of which more than ₹111 crore represented cash deposits. The assessee stated that he earned commission income from the sale of agricultural produce on behalf of farmers through two concerns. However, despite repeated notices under Section 142(1), he failed to produce books of account, vouchers, transport bills, mandi licence, or other supporting documents.
The reassessment order was passed on 20.03.2023 under Sections 147 read with 144 and 144B, wherein the Assessing Officer estimated income at six percent of the bank credits on a presumptive basis. Subsequently, the Principal Commissioner of Income-tax invoked revisionary jurisdiction under Section 263 on the ground that the reassessment order had been passed without proper enquiry and verification and was prejudicial to the interests of the Revenue. Notices were issued but the assessee did not respond. By order dated 23.03.2024, the Principal Commissioner set aside the reassessment order and directed the Assessing Officer to pass a fresh order after considering the entire bank credits of ₹123.12 crore.
