Revenue vs. Nipul Sureshchandra Mehta

Parties Involved

Facts Summary

The Revenue has appealed against the order of the Commissioner of Income Tax (Appeals) / National Faceless Appeal Centre (NFAC), dated 26.05.2025, for the Assessment Year 2017-18. The appeal arises from an assessment order passed under section 144 read with section 142(1) of the Income Tax Act, 1961, dated 06/12/2019, by ITO-33(2)(4), Mumbai. The Revenue contends that the Ld. CIT(A) erred in deleting the addition of Rs. 1,20,6,499/- as unexplained money under section 69A of the I.T. Act, 1961. The assessee, Nipul Sureshchandra Mehta, was non-compliant during the assessment but provided submissions and evidence before the Ld. CIT(A), leading to the deletion of the addition. The Revenue argues that these submissions were made for the first time before the Ld. CIT(A) and were not shared with the Ld. AO, violating Rule 46A of the Income Tax Rules, 1963.…

Legal Issues

• 1. Whether the Ld. CIT(A) erred in deleting the addition of Rs. 1,20,6,499/- as unexplained money under section 69A of the I.T. Act, 1961.

Judgment Outcome

Decided in favour of Revenue.

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