Ravipati Sunil Kumar Vs ITO (ITAT Bangalore)
The Income Tax Appellate Tribunal (ITAT), Bangalore, SMC Bench, decided the appeal filed by the assessee against the order dated 10.01.2024 passed by the Addl./JCIT(A)-2, Delhi under Section 250 of the Income Tax Act, 1961 for Assessment Year 2014-15. The appeal before the Tribunal arose from an assessment order passed under Sections 143(3) read with 147 of the Act.
Material Facts
The assessee challenged the reassessment and the appellate order on several grounds. The grounds included objections to the reopening under Sections 147 and 148, the alleged absence of valid “reason to believe,” and the addition of ₹4,14,94,367/- made by the Assessing Officer. The assessee contended that the addition represented capital introduced while he was residing and working in the United Arab Emirates and that he possessed sufficient sources of investment. The assessee also challenged the addition of 30% of the capital introduced, contending that it was made without proper legal basis and without supporting evidence, and alleged violation of principles of natural justice.
Before the Tribunal, however, the primary issue initially considered was the delay of 648 days in filing the appeal.
Procedural Background
The assessee submitted an application dated 22.12.2025 seeking condonation of the delay of 648 days. Along with the application, death certificates relating to the assessee’s father and father-in-law were produced.
