ITAT Restores ₹15 Crore Cash Addition: CIT(A) Failed to Seek Remand Report & Violated Rule 46A

ITO Vs Baldev Prasad Patel (ITAT Raipur) CIT(A) Deleted ₹15.81 Cr Addition Based on Fresh Evidence Without Remand Report—Matter Remanded Back for Rule 46A Violation Revenue challenged the NFAC order dated 07.08.2025 whereby the CIT(A)/NFAC deleted an addition of Rs.15,81,34,560/- made u/s 69A. Assessee had neither filed a return nor responded to notices u/s 148 & 142(1), due to which the AO completed reassessment u/s 147 r.w.s 144 r.w.s 144B based on huge cash deposits in a Punjab National Bank account. CIT(A)/NFAC accepted fresh evidences-including communications from PNB & detail...