NRI Couldn’t Access Documents in Time — ITAT Restores Property Addition for Fresh Examination

Brijeshkumar Natvarlal Patel Vs ITO (ITAT Ahmedabad)

Assessee, an NRI settled in the USA since 2001, had purchased an immovable property for ₹66.95 lakh. Since no return was filed, & information showed the property purchase, the AO reopened the case u/s 148. During reassessment, Assessee did not respond to notices, except for one letter stating he was unaware of proceedings & needed time to collect documents from India. AO completed the assessment ex parte, treating the entire investment as unexplained u/s 69A.

Assessee appealed late by 312 days, explaining that he

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