Hanoze Harish Thakkar vs. Income Tax Officer

Parties Involved

Facts Summary

The assessee, Hanoze Harish Thakkar, filed an appeal against the order dated 18/12/2025 passed by the National Faceless Appeal Centre (NFAC), Delhi, for Assessment Year 2014-15. The assessee challenged the additions made by the Assessing Officer under various heads, including salary income, interest income, commission income, and estimated business income. Additionally, the assessee contested the addition of Rs. 2,22,66,300/- under section 69 of the Income Tax Act, 1961, alleging unexplained investment in immovable property. The assessee also sought credit for tax deducted at source (TDS) amounting to Rs. 17,78,988/-. The assessment order dated 30/03/2022 was passed ex parte by the Assessing Officer, and the appeal by the assessee was also disposed of ex parte by the Commissioner of Income Tax (Appeals).…

Legal Issues

• 1. Whether the Commissioner of Income Tax (Appeals) erred in upholding the action of the Assessing Officer in making additions based on Form 26A without considering the factual and legal matrix of the case.
• 2. Whether the Commissioner of Income Tax (Appeals) erred in upholding the addition of Rs. 2,22,66,300/- under section 69 of the Act without examining relevant facts and supporting material.
• 3. Whether the Commissioner of Income Tax (Appeals) erred in not granting credit for TDS amounting to Rs. 17,78,988/-.
• 4. Whether the Commissioner of Income Tax (Appeals) erred in upholding the action of the Assessing Officer in reopening the assessment in violation of sections 147 to 151 of the Act.

Judgment Outcome

Decided in favour of Assessee.

Precedents Relied Upon

Similar Judgements

• Johnson Neduvelil John vs. The Income Tax Officer - 2(1)

  Cochin bench

• Velayudhanparambil Kumran Rajeevan vs. The Income Tax Officer

  Cochin bench

• Sajeendran Sadanandan vs. The Income Tax Officer

  Cochin bench

• Nikunjkumar Narbheram Thakkar Vs. The Income Tax Officer

  Ahmedabad bench

• Nanak Motumal Pherwani vs. Income Tax Officer

  Surat bench

• Hareshkumar Hashmukhlal Shah Vs. Income Tax Officer

  Ahmedabad bench