Vyome Mehta Vs ITO (Allahabad High Court)
Summary: The Allahabad High Court considered a challenge to reassessment proceedings for A.Y. 2022-23 initiated against the petitioner, who described himself as a salaried employee of a private Corporation and denied having carried on any business activity. He had filed his return declaring annual income of Rs.4,15,630/- and stated that he had no other income.
A show cause notice dated 30.3.2026 under Section 148-A(1) referred to information derived through the Income Tax Portal under the risk management strategy. The information linked transactions to the petitioner’s PAN, including a purchase transaction by a dummy entity of Rs.11,16,10,199, total sales reported under GSTR-1 of Rs.24,03,22,375, total sales reported under GSTR-3B of Rs.29,46,36,781, and a TDS statement for professional services or royalty of Rs.5,83,597. The notice also recorded that the return of income filed on 17.07.2022 declaring Rs.4,15,630/- did not commensurate with those transactions.
The petitioner denied the business transactions, denied knowledge of Hari Om Traders, described as his proprietary concern, and denied association with its stated business address. He stated that his identity may have been stolen while submitting online loan applications. He also relied on an e-mail dated 29.4.2026 from the GST Authorities, which stated that registration of M/s Hari Om Traders had been obtained using PAN and Aadhaar documents pertaining to Sh. Vyome Mehta, that the firm was not found at the stated principal place of business during field inspection, and that its registration was subsequently cancelled. The GST communication also stated that the firm had operated for three months, October 2021 to December 2021, before the registration was suo moto cancelled from its date of registration.
