Addition based on non-service of notices set aside – Mumbai ITAT accepts source of property funds

Roma Prakash Chhugani Vs ITO (ITAT Mumbai) Assessee,  a senior citizen & housewife, was subjected to reassessment proceedings u/s 147, with a best judgment assessment made u/s 144 r.w.s. 147, adding ₹1.36 crore as unexplained investment u/s 69C for the purchase of a flat. She had not filed an income tax return & the assessment was done ex-parte, as she did not receive any statutory notices due to a change of address. She came to know about the assessment only after her bank account was attached by the department. In appeal, she submitted that the flat was purchased jointly with ...