AIR-Based Reopening Sends NRI Investment Case Back to AO

Pradip Naik Vs ITO (ITAT Delhi) AIR-Based Reopening Leads to Remand: Source From Abroad Explained? ITAT Sends NRI Investment Case Back for De-novo Assessment Delhi ITAT ‘D’ Bench in Pradip Naik vs ITO (ITA No.1497/Del/2023, AY 2012-13, order dated 24-12-2025) set aside the orders of the lower authorities and remanded the matter to the AO for de-novo adjudication, holding that the source of NRI’s mutual fund investments requires fresh verification. The assessee, an NRI engaged in business in Oman since 1985, did not file a return for AY 2012-13. Based on AIR information of bank deposits a...