Grish Roy Pandit Vs ITO (ITAT Delhi)
The appeal was filed against the order dated 31.08.2025 passed by the National Faceless Appeal Centre (NFAC) for Assessment Year 2015–16, arising from an assessment completed under Sections 147 and 144B of the Income-tax Act. The assessee challenged the reopening of assessment, alleged non-compliance with statutory provisions, non-faceless issuance of notice under Section 148, addition of ₹1 crore as unexplained income, and violation of principles of natural justice.
The case originated from information flagged under the Risk Management Strategy regarding a high-value transaction. The assessee had sold a one-fourth share in an immovable property for ₹1 crore but had not initially filed a return of income. Consequently, notice under Section 148A(b) was issued, followed by an order under Section 148A(d) and notice under Section 148 when no response was received. The matter was thereafter handled by the Faceless Assessment Unit under Section 144B.
The assessee subsequently filed a belated return on 28.02.2023 declaring total income of ₹68,20,080 under long-term capital gains. During assessment, documents including sale deed, purchase deed, computation of income, and bank statements were furnished. On verification, the Assessing Officer found that the assessee’s share of ₹1 crore from the property sale was duly disclosed and the corresponding income had been offered to tax. No addition was made in the final assessment order, and income was accepted as declared.
