Anupam Shailesh Syal Vs ITO (ITAT Surat)
In a significant procedural ruling, the Income Tax Appellate Tribunal (ITAT), Surat Bench, has set aside an ex-parte order from the Commissioner of Income-tax (Appeals) [CIT(A)] that had confirmed an addition of over ₹11 lakh to the income of Anupam Shailesh Syal for the Assessment Year (AY) 2012-13. The Tribunal’s decision, dated July 21, 2025, remands the case back to the CIT(A) for a fresh hearing, citing a violation of the principles of natural justice. While granting the assessee another opportunity, the ITAT also imposed a penalty of ₹10,000, underscoring the assessee’s repeated failure to cooperate with tax authorities.
The case originated from an assessment triggered by the Income Tax Department’s Non-Filer Monitoring System (NMS). Data from the Annual Information Return (AIR) and Central Information Branch (CIB) revealed that Ms. Syal, who had not filed an income tax return for the AY 2012-13, had engaged in stock transactions totaling ₹11,16,526. Following this discovery, the Assessing Officer (AO) issued a notice under Section 133(6) of the Income-tax Act, 1961, on March 4, 2019, requesting details of these transactions. When the assessee failed to respond, the AO concluded that the entire amount represented undisclosed and unexplained income that had escaped assessment.
