Rahulkumar Narshibhai Patel filed an appeal before the Income Tax Appellate Tribunal (ITAT), Ahmedabad, for Assessment Year 2019-20 against the order of the Income Tax Officer, challenging additions made under sections 69A, 147 and 148 dated 24 April 2026. The appeal was against the CIT(A) order, which had given only partial relief but still upheld major additions, sending the matter back to the Assessing Officer for fresh examination and verification.

The assessee in this case is a Non-Resident Indian (NRI) who works in Kuwait and draws a salary from there. The Income Tax Department received information through SFT (Statement of Financial Transactions) that a large amount of money has been deposited in the bank accounts of the assessee located in India. In this, an amount of Rs 2,49,75,347/- has been shown in HDFC Bank, Rs 1,09,63,510/- in ICICI Bank and Rs 3,77,711/- in ICICI Prudential. Since the assessee had not filed the income tax return of the relevant year, the department reopened the case under section 147.

The Assessing Officer asked the assessee to explain the source of these amounts, but the assessee could not submit complete information and documents. Only partial details of the NRE account were given, due to which a satisfactory explanation could not be given. For this reason, the AO assessed the entire amount of Rs 36,316,568/- as undisclosed income under section 69A.

The assessee subsequently appealed before the CIT(A) and submitted additional evidence, including statements of the National Bank of Kuwait, salary statements and NRE accounts in India. Investigation found that an amount of Rs 1,04,11,345/- in ICICI Bank had come from foreign income, which was accepted. The amount of Rs 377,711/- of ICICI Prudential was only the policy value; hence, the same was also removed. However, for the amounts of Rs 5,52,165/- of ICICI Bank and Rs 2,49,75,347/- of HDFC Bank, clear evidence was not given; Finally, the CIT(A) upheld them.

The ITAT, while re-reviewing the case, found that the small amount owed by ICICI Bank was only due to a lack of reconciliation and was therefore appropriate to be struck off. Neither the assessee nor the department could give clear information regarding the huge amount in the HDFC Bank. Finally, the issue was sent back to the AO for re-examination. Thus, partial relief was provided to the assessee.