Sohil Patel Vs ITO (ITAT Ahmedabad)
In the case of Sohil Patel Vs. ITO before the ITAT Ahmedabad, the assessee filed an appeal against the order dated February 8, 2024, passed by the Ld. Commissioner of Income Tax (Appeals) (NFAC) for the assessment year 2010-11. The core issue involved the addition of Rs. 51,76,670 made by the tax authorities, citing unexplained investment in an immovable property. The assessee challenged the addition, arguing that there was non-compliance with notices due to genuine reasons. The appellant, who resided in a rural area, was illiterate and not familiar with computers or emails, leading to the failure in responding to the notices issued by the authorities.
The appeal stemmed from a discrepancy in the reported value of the property, with the assessee’s share being Rs. 31,25,000, while the stamp duty valuation was Rs. 51,76,670. The Ld. CIT(A) had summarily dismissed the assessee’s appeal due to non-compliance, which led the ITAT Ahmedabad to reconsider the case. The appellant’s counsel requested a chance to comply with the notices and presented the willingness to pay a nominal cost towards the “Prime Minister Relief Fund.” The Ld. DR, acknowledging the issues raised by the appellant, agreed that the matter should be remanded for a fresh hearing.
