Pavan Prabhudyal Bhadada Vs ITO (ITAT Ahmedabad)
The Income Tax Appellate Tribunal (ITAT), Ahmedabad, considered an appeal by Pavan Prabhudyal Bhadada against the Principal Commissioner of Income Tax’s (PCIT) order concerning Assessment Year 2016-17. The PCIT had invoked section 263 of the Income-tax Act, revising the original assessment order. The PCIT’s action was based on findings from a search at Shri Renuka Mata Multi State Urban Co-operative Society, which revealed that the assessee had deposited Rs. 1,27,75,311/- into an account with the society.
The PCIT observed that the Assessing Officer (AO) had accepted the assessee claim of lacking knowledge about these transactions and did not include the deposit amount in the assessee income. However, the PCIT determined that the AO failed to adequately examine these unexplained deposits, which constituted unaccounted investment. The ITAT addressed arguments from the assessee counsel, including claims that the PCIT’s action was incorrect, that the AO had considered submitted information, and that the PCIT did not provide a personal hearing. A new argument was presented, stating the assessee father operated the account without the assessee knowledge. The ITAT found that the AO did not sufficiently inquire into the source of the deposits and that this new argument was not raised earlier. Ultimately, the ITAT found no error in the PCIT’s order and dismissed the assessee appeal.
