Income Tax Appellate Tribunal - Ahmedabad
Reshmaben Chunara,Vadodara vs The Ito, Ward-3(1)(4), Vadodara on 24 March, 2026
IN THE INCOME TAX APPELLATE TRIBUNAL
"SMC" BENCH, AHMEDABAD
BEFORE DR. B.R.R. KUMAR, VICE-PRESIDENT
I.T.A. No.2643/Ahd/2025
(Assessment Year: 2019-20)
Resmaben Chunara, The Income Tax Officer,
Chunarawad, Near Cambe Show Vs.
Ward 3(1)(4),
Mill, Opp. Baranpura Petrol Vadodara.
Pump, Vadodara
Gujarat-390 001
[PAN : CAIPC5594В]
(Appellant) .. (Respondent)
Appellant by : Shri Parimalsinh B. Parmar, A.R.
Respondent by: Shri Arvind Kumbhare, Sr. D.R.
Date of Hearing 19.03.2026
Date of Pronouncement 24 .03.2026
ORDER
PER DR. B.R.R. KUMAR, VICE-PRESIDENT:-
Delay Condoned The captioned appeal has been filed by the Assessee against the order passed by the Ld. Commissioner of Income Tax (Appeals), National Faceless Appeal Centre (in short "NFAC"), Delhi vide order dated 26.02.2025 relevant to Assessment Year 2019-20.
2. The Assessee has raised the following grounds of appeal:
1. The Ld. CIT(A) has erred, both in law and on facts, in passing ex-parte order which is in gross violation of the principles of natural justice.
2. The Ld. CIT(A) has erred, both in law and on facts, in confirming action of AO in reopening the assessment under section 147 of the Act.
3. The Ld. CIT(A) has erred, both in law and on facts, in confirming the addition of Rs.15,00,000/- made by AO in respect of alleged unexplained investment.
4. Both, AO & CIT(A), have erred in passing the impugned orders without properly appreciating facts of the case, submissions of the assessee and ITA No. 2643/Ahd/2025 Asst. Year : 2019-20
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documentary evidences available on record in the correct perspective. Such an act is in gross violation of the principles of natural justice.
5. The Ld. CIT(A) has erred in law and on facts of the case in confirming levy of interest u/s. 234A/B/C of the Act.
6. The Ld. CIT(A) has erred in confirming action of initiation of penalty proceedings under section 271AAC(1) of the Act.
7. The Ld. CIT(A) has erred in confirming action of initiation of penalty proceedings under section 234F of the Act.
8. The appellant craves leave to add, amend, alter, edit, delete, modify or change all or any of the grounds of appeal at the time of or before the hearing of the appeal.
3. Brief facts of the case involve that; the assessee carried out vegetable business in redi during the year under consideration. The business involves daily purchase and sale of vegetables. The appellant carries out such vegetable business since many years. The appellant has never filed return of income as she was not having any taxable income. The appellant purchased immovable property of Rs. 19,00,000/- during the year under consideration. The AO passed assessment order u/s 147 r.w.s. 144 of the Act dt: 15.03.2024 with addition of unexplained investment of Rs. 15,00,000/-.
4. I find that the assessee has purchased a property at Baranpura, Baroda along with her brother. The amount of Rs.3,00,000/- has been paid on 05.06.2018 and Rs. 2,00,000/- paid on 09.07.2018. The assessee received an amount of Rs.4,00,000/- on 15.06.2018 and Rs.6,00,000/- 26.06.2018 from the brother-in-law Rajubhai Chunara and the amounts have been paid directly to the property owner Bhartiben Parikh. Rajubhai Chunara has obtained loan on FD and cash withdrawal to prove the availability of monies of Rs.10,00,000/- paid for the purchase of the property. Since the source of amounts invested for purchase of property ITA No. 2643/Ahd/2025 Asst. Year : 2019-20
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5. In the result, the appeal filed by the assessee is allowed.
The order is pronounced in the open Court on 24.03.2026.
Sd/- Sd/-
(DR. B.R.R. KUMAR)
VICE-PRESIDENT
(True Copy)
Ahmedabad; Dated 24.03.2026
MV
आदे श की ितिलिप अ े िषत/Copy of the Order forwarded to :
1. अपीलाथ / The Appellant
2. थ / The Respondent.
3. सं बंिधत आयकर आयु / Concerned CIT
4. आयकर आयु (अपील) / The CIT(A)-
5. िवभागीय ितिनिध, आयकर अपीलीय अिधकरण, अहमदाबाद / DR, ITAT, Ahmedabad
6. गाड फाईल / Guard file.
आदे शानुसार/ BY ORDER, True Copy सहायक पंजीकार (Dy./Asstt. Registrar) आयकर अपीलीय अिधकरण, अहमदाबाद / ITAT, Ahmedabad