Shabbir Husainibhai Rajkotwala Lifeline Hospital Vs ITO (ITAT Surat)
The appeal was filed by the assessee against the order dated 17.11.2025 passed by the Commissioner of Income Tax (Appeals), National Faceless Appeal Centre, Delhi, arising from a reassessment order passed under Section 147 read with Section 144B of the Income-tax Act, 1961 for Assessment Year 2018-19.
The assessee, an individual and a doctor by profession, had filed the return of income declaring total income of Rs. 2,76,600/-. The assessment was reopened by issuance of notice under Section 148 on 09.04.2022 on the ground that there were substantial financial transactions not reflected in the return of income. During the reassessment proceedings, the assessee explained the financial transactions. However, the Assessing Officer made an addition of Rs. 5,00,000 under Section 68 of the Act in respect of an unsecured loan received from Shri Naranlal Soni and also subjected the amount to tax under Section 115BBE.
The CIT(A) confirmed the addition. According to the appellate order, the lender had deposited cash of Rs. 5,01,000 on 05.01.2018 and thereafter issued a cheque of Rs. 5,00,000 to the assessee. The CIT(A) also noted that the balance in the lender’s bank account before the transaction was only Rs. 143.75 and that the lender’s return of income disclosed total income of Rs. 4.53 lakh, leading to confirmation of the addition.
