Jitendra Amrutlal Patel Vs ITO (ITAT Ahmedabad)
Income Tax Appellate Tribunal (ITAT) Ahmedabad has upheld the addition of ₹4.64 crore to the taxable income of Jitendra Amrutlal Patel under Section 69A of the Income Tax Act, 1961. The case involved high-value unexplained transactions in two bank accounts that were flagged during an investigation. The Assessing Officer (AO) initiated reassessment under Section 147, but the assessee failed to respond to repeated notices under Section 148. Due to continued non-cooperation, the AO proceeded with an ex-parte assessment, treating the unexplained amounts as undisclosed income and levying tax accordingly. The assessee then appealed before the Commissioner of Income Tax (Appeals) [CIT(A)], but failed to provide any supporting documents or explanations, leading to the dismissal of the appeal.
The ITAT noted that despite multiple opportunities before both the AO and CIT(A), the assessee neither appeared for hearings nor submitted evidence. Even before the Tribunal, the assessee repeatedly sought adjournments without valid reasons, showing a lack of intent to pursue the appeal. The Tribunal cited a Gujarat High Court judgment in a similar case, where non-cooperation by the assessee led to the confirmation of the assessment order. Following this precedent, the ITAT found no reason to interfere with the lower authorities’ decisions and dismissed the appeals.
