Shantaben Joitaram Patel Vs ITO (ITAT Ahmedabad)
This appeal was filed by the assessee against the appellate order dated 11.03.2025 passed by the Commissioner of Income Tax (Appeals), National Faceless Appeal Centre, Delhi, arising from an ex parte reassessment order under Sections 147 read with 144 of the Income Tax Act, 1961 for Assessment Year 2012-13.
The assessee, a 76-year-old retired teacher and widow, had not filed her return of income for AY 2012-13 on the ground that she had no taxable income. Her children had migrated to Canada in 2004, and she was residing alone in India until 2012. During Financial Year 2011-12, she sold her old house and purchased a new house for Rs. 42,00,000. As no return was filed and an investment of Rs. 42,00,000 was made in immovable property, the assessment was reopened by issuing notice under Section 148.
In reassessment proceedings, the assessee produced documents supporting Rs. 28,00,000 of the investment. The Assessing Officer treated the remaining Rs. 14,00,000 as unexplained investment and made an addition accordingly.
The assessee challenged the reassessment before the CIT(A) and filed additional documents. The CIT(A) called for a remand report from the Assessing Officer but ultimately confirmed the addition of Rs. 14,00,000.
