Sohanvir Singh Vs ITO (ITAT Delhi)
The Income Tax Appellate Tribunal (ITAT), Delhi Bench, recently allowed an appeal by Sohanvir Singh against an order passed by the National Faceless Appeal Centre (NFAC), remitting the matter back to the Assessing Officer (AO). The ITAT’s decision, pronounced on January 17, 2025, hinged on the grounds that the assessee was not provided with an adequate opportunity to be heard during the assessment proceedings and the subsequent appeal before the NFAC.
The case originated with Mr. Singh filing his income tax return for the assessment year 2017-18, declaring a total income of ₹2,85,200. The return was selected for limited scrutiny under the Computer Assisted Scrutiny Selection (CASS) to examine the source of a cash deposit made during the financial year. Consequently, the AO issued notices under Section 143(2) and Section 142(1) of the Income-tax Act, 1961.
However, according to the assessee, there was no response to these notices as a wrong email ID was allegedly on record. Consequently, the AO proceeded to pass a best judgment assessment under Section 144 of the Act, adding back ₹84,61,500, representing the cash deposit, as unexplained income under Section 69A of the Act. This resulted in a total income assessment of ₹87,46,700.
