Gold Palace Jewellers Vs ACIT (ITAT Bangalore)
₹2.44 crore cash deposit addition confirmed by CIT(A)without proper opportunity: ITAT Orders Fresh Adjudication
In the case of Gold Palace Jewellers Vs ACIT, the Income Tax Appellate Tribunal (ITAT) Bangalore addressed an appeal filed by the assessee, a partnership firm engaged in gold and diamond jewelry trading. The case revolved around unexplained cash deposits of ₹2.44 crore during the demonetization period, which the Assessing Officer (AO) had taxed under Section 69A of the Income Tax Act. Dissatisfied with the AO’s assessment, the firm appealed to the Commissioner of Income Tax (Appeals) [CIT(A)], filing electronically in January 2020. However, the CIT(A) passed its order in July 2024—a delay of over four years—without granting the firm adequate opportunity for a hearing.
The ITAT observed that the prolonged delay and failure to follow principles of natural justice rendered the appellate order deficient. Agreeing with the assessee’s contentions, the ITAT remitted the case back to the CIT(A) for fresh adjudication. The tribunal instructed the CIT(A) to provide a fair hearing and directed the assessee to submit all necessary documentation while avoiding unnecessary adjournments. This decision underscores the importance of timely disposal of appeals and adherence to procedural fairness in tax adjudication.
