PRADEEP KUMAR NARSARIA,RANCHI V. ITO, WARD 2(1), RANCHI

ITA 65/RAN/2025

AI Insights

This case involves an appeal by Pradeep Kumar Narsaria against the order of the CIT(A), NFAC, Delhi, concerning the assessment year 2015-16. The primary contention revolves around the reopening of the assessee's income tax assessment by the Assessing Officer, which was based on alleged cash deposits of ₹ 2.05 crores in a bank account. The assessee contested that the cited account number belonged to a savings account at State Bank of India, not a current account at Corporation Bank as claimed by the Assessing Officer. The Tribunal noted discrepancies in the bank account numbers and the amounts cited, leading to the decision to restore the matter to the Assessing Officer for a thorough re-examination.

• Counselvise Citation: [2026] 140 COUNSELVISE.COM (IT) 826242 (ITAT-RANCHI)
• Duration Of Justice: 9 month(s) 15 day(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 06-01-2026
• Appeal Filed By: Assessee
• Order Result: Partly Allowed
• Bench Allotted: DB
• Assessment Year: 2015-2016
• Appeal Filed On: 21-03-2025
• Result in Favour of: Partly Allowed
• Court: TRIBUNAL
• Keywords: Opportunity of being heard

Judgement Text

"IN THE INCOME TAX APPELLATE TRIBUNAL, RANCHI BENCH, RANCHI BEFORE SHRI GEORGE MATHAN, JUDICIAL MEMBER AND SHRI RATNESH NANDAN SAHAY, ACCOUNTANT MEMBER ITA No. 65/Ran/2025 (Assessment Year-2015-16) Pradeep Kumar Narsaria, Opp. Income Tax Colony, H.B. Road, Lalpur, Ranchi-834001. PAN No. AAKPN 8455 G Vs. I.T.O., Ward-2(1), Ranchi. Appellant/ Assessee Respondent/ Revenue Assessee represented by Shri Devesh Poddar, A.R. Department represented by Shri R.C. Marndi, Sr.DR Date of hearing 06/01/2026 Date of pronouncement 06/01/2026 O R D E R PER: BENCH 1. This is an appeal filed by the assessee against the order of the ld. CIT(A), NFAC, Delhi in Appeal No. NFAC/2014-15/10165834 dated 27/09/2023 for the A.Y. 2015-16. 2. Shri Devesh Poddar, ld. A.R. is represented on behalf of the assessee and Shri R.C. Marndi, ld. Sr.DR represented on behalf of the revenue. 3. It was submitted by the ld. AR that the assessee is operating a small Dish-TV Recharge shop. It was a submission that the assessee had filed its return of income disclosing an income of ₹ 3,04,524/-. It was a submission that the Assessing Officer had reopened the assessment of the assessee on the ground that there was cash deposit of ₹ 2.05 crores in the bank account No. 62282357559 maintained with corporation Bank, Hazaribagh. It was a submission that the assessee does not have such an account with Corporation Bank. It was a submission that the account of the assessee with Corporation Printed from counselvise.com ITA No. 65/Ran/2025 Pradeep Kr Narsaria vs ITO 2 Bank is a Current Account having account No. CBCA/01/000152. It was a submission that the said bank account number referred to by the Assessing Officer is the savings bank account of the assessee with the State Bank of India, Lalpur. It was a submission that the cash deposits in the said Corporation Bank was amount of ₹ 1,26,87,955/-. It was a submission that there was no cash deposit in the savings bank account of the assessee with the State Bank of India. It was a submission that the reasons recorded for the reopening are invalid and the assessment is liable to be quashed. The ld. AR has placed before us the copy of his current account with Corporation Bank which reads as follows: Printed from counselvise.com ITA No. 65/Ran/2025 Pradeep Kr Narsaria vs ITO 3 The assessee's savings bank account with State Bank of India which reads as follows: Printed from counselvise.com ITA No. 65/Ran/2025 Pradeep Kr Narsaria vs ITO 4 4. In reply, the ld. Sr. DR submitted that in the course of assessment, there was non-cooperation by the assessee. It was also a submission that before the ld. CIT(A) also, there is non-cooperation by the assessee. It was a submission that if at all the issues may be restored to the file of the Assessing Officer for verification and readjudication. Printed from counselvise.com ITA No. 65/Ran/2025 Pradeep Kr Narsaria vs ITO 5 5. In reply, the ld. Authorised Representative submitted that if the issues were being restored to the file of the Assessing Officer for readjudication, the legal issues as raised by the assessee should be left open. 6. We have considered the rival submissions. A perusal of the facts in the present case clearly shows that in the reasons recorded, admittedly the Assessing Officer has referred to the bank account number of the savings bank account but the transactions from the Current Account maintained with the Corporation Bank. It was also noticed that the figure of ₹ 2.05 crores arrived at by the Assessing Officer is not available in any of the bank accounts that have been produced before the Tribunal. However, as it is noticed that this is an ex parte order before the Assessing Officer as also before the ld. CIT(A), in the interest of justice, the issues in this appeal are restored to the file of Assessing Officer for readjudication after granting the assessee adequate opportunity of being heard. All the legal issues are left open. 7. In the result, this appeal of the assessee is partly allowed for statistical purposes. Order announced in open court on 06/01/2026. Sd/- Sd/- (RATNESH NANDAN SAHAY) (GEORGE MATHAN) ACCOUNTANT MEMBER JUDICIAL MEMBER Ranchi, Dated: 06/01/2026 *Ranjan Copy to: 1. Assessee 2. Revenue 3. CIT 4. DR By order 5. Guard File Sr. Private Secretary, ITAT, Ranchi Printed from counselvise.com "