Chandra Khilwani Vs ITO (ITAT Ahmedabad)
In Chandra Khilwani Vs ITO (ITAT Ahmedabad), the assessee appealed against the order dated 24-09-2025 passed by the Commissioner of Income Tax (Appeals), National Faceless Appeal Centre, Delhi, arising from reassessment proceedings under Sections 147 read with 144B of the Income Tax Act, 1961 for Assessment Year 2019-20.
The assessee, a retired school teacher, had not filed a return of income for A.Y. 2019-20 as her income was below the taxable limit. During a survey under Section 133A conducted on 30-05-2019 at the premises of a builder group, a loose Excel sheet was found containing alleged “cash payment details.” The Assessing Officer (AO) noted that shop numbers 17 to 20 reflected cash payments totaling Rs.52,00,000/- and cheque payments of Rs.40,00,000/-, and the assessee’s name and PAN appeared against shop no. 19. A notice under Section 148A(b) was issued alleging escaped income of Rs.55,81,008/-.
In response, the assessee stated that she had not purchased any property during financial year 2018-19 and had instead purchased one shop in July 2021 in a different project, with the sale deed executed in October 2021. She clarified that the entire consideration was paid through cheque from her SBI and Post Office accounts and produced the registered sale deed dated 13-10-2021. She denied making any cash payment.
