Gautam Kumar Singh Vs ITO (ITAT Agra)
Reopening Needs Application of Mind—Not Just an Approval Stamp
The dispute: Property purchased, additions followed
The assessee filed his return for AY 2020-21, declaring income of ₹5,46,990, which was processed under section 143(1). Subsequently, the Department received information that he had purchased an immovable property for ₹1,62,000, whereas its stamp duty value was ₹20,08,000. Reassessment proceedings were initiated, culminating in an assessment order dated 20 March 2025.
The Assessing Officer made two additions. The purchase consideration of ₹1,62,000 was added under section 69, holding that the source of investment remained unexplained. The difference of ₹18,46,000 between the stamp duty value and the purchase consideration was added under section 56(2)(x)(b). The CIT(A), NFAC, confirmed both additions, leading to the appeal before the Tribunal.
A short delay, sufficiently explained
The appeal before the Tribunal was delayed by approximately 24 days. The assessee explained that he was not technologically proficient and became aware of the appellate order only when his consultant accessed the income-tax portal on 4 March 2026.
The explanation was supported by an affidavit and remained uncontroverted. The Tribunal accepted it as sufficient cause, condoned the delay and admitted the appeal. The matter was thus examined on its legal merits rather than being shut out at the threshold.
