Question 1

What are the key legal issues in Dhiren B Patel vs The Deputy Commissioner of Income Tax?

Accepted Answer

1. Addition of unexplained income under Section 69 of the Act 2. Addition of interest income beyond income reported in Form 26AS

Question 2

What are the facts of Dhiren B Patel vs The Deputy Commissioner of Income Tax?

Accepted Answer

The present appeal has been preferred by the Assessee challenging the Order, dated 19/07/2024, passed by the Learned Commissioner of Income Tax, Appeal - Ahmedabad-13 whereby the Learned CIT(A) had dismissed the appeal against the Assessment Order, dated 26/09/2019, passed under Section 144 of the Income Act, 1961 for the Assessment Year 2017-2018. The Assessee has raised the following grounds of appeal: 1. That, the Ld. CIT (A) has wrongly confirmed the addition of alleged unexplained invest u/s 69 of the Act of Rs.10,72,000/-. 2. That, the Ld. CIT (A) has wrongly confirmed the addition of income from other sources being interest Income Rs. Rs. 1,39,021/- beyond income reported in Form 26AS. 3. That, the Ld. CIT (A) has wrongly confirmed application of provisions of section 115BBE of the I.T. Act, 1961. 4. That, the Ld. CIT (A) has wrongly confirmed levy of penalty u/s 271AAC and 271F of the I.T. Act, 1961. 5. That, the Ld. CIT (A) has wrongly charged interest u/s 234A and 234B, of the I. T. Act, 1961. We have heard both the sides on the grounds raised and have perused the material on record. It emerges that for the Assessment Year 2017-2018 reassessment proceedings were initiated in the case of the Assessee under Section 147 of the Act on the basis of information to the effect that cash deposit of INR.10,72,000/- was made in the Non-Resident Ordinary (NRO) Bank account (held jointly by four members: the Assessee, his wife, and his parents) with Bank of Baroda (specialized N

Dhiren B Patel vs The Deputy Commissioner of Income Tax

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