CIT(A) Had No Material to Examine – Assessee Gets Final Opportunity to Prove Capital Source

Urvashiben Sunilbhai Amin Vs ITO (ITAT Ahmedabad) Assessee, proprietor of M/s New SK Engineering Works, filed ROI declaring ₹4,90,538. Limited Scrutiny was triggered for mismatch in 26AS, turnover mismatch & substantial capital increase. In assessment u/s 143(3), AO repeatedly sought capital accounts & evidence of capital introduction. Assessee stated no capital was introduced in FY 2014-15 but failed to furnish capital accounts. AO analysed ITRs of AYs 2013-14 to 2015-16 & reconstructed capital, determining that disclosed capital of ₹1,24,15,536 as on 31.03.2015 exceeded expla...