Umeshbhai Ramanlal Shah Vs ITO (ITAT Ahmedabad)
Income Tax Appellate Tribunal (ITAT), Ahmedabad Bench, on June 26, 2025, restored a case involving unexplained cash deposits of ₹18,32,350/- to the Assessing Officer (AO). The appeal, filed by Umeshbhai Ramanlal Shah against an order from the National Faceless Appeal Centre (NFAC), challenged the addition made under Section 69A of the Income Tax Act, 1961, for Assessment Year 2011-12. The ITAT’s decision highlighted the AO’s failure to adequately examine debit entries in the bank account and the CIT(A)’s oversight in not admitting or properly considering additional evidence presented by the assessee.
The genesis of the case lies in the fact that the assessee, a non-resident, had not filed a return of income for AY 2011-12. The AO received information indicating a cash deposit of ₹18,32,350/- in the assessee’s savings bank account with Bank of Baroda during the Financial Year 2010-11. Based on this, the case was reopened under Section 147, and a notice under Section 148 was issued. Due to non-compliance from the assessee, purportedly because he was out of the country and unaware of the proceedings, the assessment was completed ex-parte under Section 144 read with Section 147 on December 4, 2018, with the entire cash deposit treated as income.
