Abhishek Dixit Vs ADIT/DDIT (In. Tax) Noida

Parties Involved

Facts Summary

This appeal by the assessee, Abhishek Dixit, is directed against the order of the Ld. Commissioner of Income Tax (Appeal), Noida-2, dated 29.11.2024, arising out of the assessment order dated 27.05.2022 passed under Section 147 r.w.s. 144C(3) of the Income Tax Act, 1961 by the DDIT / ADIT, International Taxation, Noida. The case was reopened u/s 147 of the Act vide notice dated 30.03.2021 due to the assessee not filing a return of income for the relevant assessment year and making a transaction of Rs. 2,87,04,714/- in property during F.Y. 2015-16, the source of which was unexplained. In response to the notice, the assessee filed a return of income on 05/05/2021 declaring a gross total income of Nil and claimed exempt income of Rs. 35,43,224/-. The AO accepted the explanation regarding the source of the investment but held that the assessee’s income amounting to Rs. 35,43,224/- would be taxable in India on account of his residential status being treated as a resident.…

Legal Issues

• 1. Whether the addition of Rs. 35,43,224/- made by the AO is sustainable in law after accepting the explanation for the property transaction.

Judgment Outcome

Decided in favour of Assessee.

Precedents Relied Upon

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