Dhiraj Singh vs. ITO, Shajapur

Parties Involved

Facts Summary

Dhiraj Singh, a non-filer, was assessed under section 147 of the Income Tax Act 1961, resulting in an assessment order dated 28.02.2023. Singh did not file a return of income and did not respond to notices issued by the Assessing Officer. The Assessing Officer completed a best-judgment assessment under section 144, making an addition of Rs. 1,31,22,400/- on account of unexplained money under section 69A. Singh, aggrieved by the assessment order, filed an appeal before the Commissioner of Income Tax (Appeals) which was dismissed. Singh then filed a second appeal before the Income Tax Appellate Tribunal. The tribunal heard the appeal on 17.08.2026 and pronounced the judgment on 09.09.2026.…

Legal Issues

• 1. Whether the reassessment order dated 28.02.2023 is bad in law, without jurisdiction, and liable to be quashed.
• 2. Whether the additions were made on mere conjectures, surmises, and suspicions.
• 3. Whether the reassessment was completed without complying with the statutory requirements of law.
• 4. Whether the reassessment order dated 28.02.2023 is contrary to law, facts, and circumstances of the case and in any case is opposed to the principles of equity, natural justice, and fair play.

Judgment Outcome

Decided in favour of Partly Assessee / Partly Revenue.

Precedents Relied Upon

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