Harpreet Singh Vs ITO (ITAT Amritsar)
Submissions on Record, Yet “Nothing Filed”: ITAT Rejects Mechanical Addition
Evidence Cannot Be Acknowledged and Then Ignored
The Amritsar Tribunal has set aside an appellate order confirming an addition of ₹26.96 lakh under Section 69A, after finding that the departmental authorities had failed to properly consider the assessee’s submissions and documentary evidence.
The first appellate authority’s order contained a striking contradiction. It expressly acknowledged that the assessee had filed submissions and evidence on 9 April 2026 and 13 April 2026, yet proceeded to confirm the addition on the allegation that no submissions or evidence had been furnished.
The Tribunal held that the addition had been made mechanically, without proper application of mind. It restored the matter to the Assessing Officer for fresh adjudication after a reasonable opportunity of hearing.
Cash Deposits Triggered Reassessment
The assessee, a resident individual, had not filed his return of income under Section 139(1) for AY 2020-21.
Information available in the Department’s system indicated cash deposits in a bank account standing in his name. The Assessing Officer considered that the assessee had taxable receipts but had failed to file a return, and consequently reopened the assessment alleging escapement of income.
