Tanveer Ahmed Siddiqui Vs ITO (ITAT Bangalore)
The reassessment
The Assessing Officer (AO) reopened the case of Tanveer Ahmed Siddiqui for assessment year 2016–17 after receiving information about bank transactions and a property purchase. Siddiqui explained that he ran a roofing-sheet business as proprietor of Karnataka Roofing and produced business records and bank statements for the cash deposits and withdrawals.
The assessment ultimately turned on the property. The AO noted that Siddiqui and his wife, Zeeshan Naji, had purchased it jointly. Siddiqui’s balance sheet recorded ₹37,71,187 as his share of the property, but the AO added the entire ₹75,42,374 under Section 69 as an unexplained investment. The CIT(A) confirmed the addition, saying that adequate documentary evidence of the payment had not been produced.
The Bangalore ITAT found that the registered deed, balance sheet and Federal Bank entries required proper consideration. It directed the AO to verify the identified bank transactions and, if satisfied, delete the addition. The appeal was allowed on those terms.
Why the 50% share mattered
Siddiqui’s first objection was to being assessed for 100% of a jointly held property when he had recorded 50% in his books. The balance sheet showed the property as a fixed asset at ₹37,71,187. The Tribunal noted that the AO knew of this disclosure but nevertheless added the full amount in Siddiqui’s hands.
