IN THE INCOME-TAX APPELLATE TRIBUNAL, SURAT BENCH, SURAT BEFORE SHRI SANJAY GARG, JUDICIAL MEMBER &

SHRI BIJAYANANDA PRUSETH, ACCOUNTANT MEMBER आयकर अपील स.ं /ITA No.1043/SRT/2024 Assessment Year: (2014-15)

(Hybrid Hearing)

Smt Jyoti Haresh Lalwani, Vs. ITO, A-10, Riverside, Near PDPU Boys Hostel, Ward – 5, PDPU Road, Raysan, Gandhinagar, Vapi Gujarat - 382007 èथायीलेखासं./जीआइआरसं./PAN/GIR No: ABXPL1848B (Appellant) (Respondent) Appellant by Shri Mohit Balani, AR Respondent by Shri Ajay Uke, Sr. DR Date of Hearing 24/09/2025 Date of Pronouncement 11/12/2025 आदेश / O R D E R PER BIJAYANANDA PRUSETH, AM:

This appeal by the assessee emanates from the order passed under section 250 of the Income-tax Act, 1961 (in short, ‘the Act’) dated 20.08.2024 by the learned Commissioner of Income Tax (Appeals), National Faceless Appeal Centre, Delhi [in short, ‘CIT(A)’] for the assessment year (AY) 2014-15.

2. The grounds of appeal raised by the assessee are as under:

“1. Learned CIT(A) has erred in law and on the facts of the case in confirming the action of learned AO in assuming the jurisdiction u/s 147 of the Act.

2. Learned CIT(A) ought to have appreciated that ITO, Ward -5, Vapi had no territorial jurisdiction over the assessment of the Assessee and thus the assumption of jurisdiction by it was bad and untenable in the eyes of law.

3. Learned CIT(A) has erred in law and on the facts in confirming the action of AO in making an addition of Rs.25,00,000/- as unexplained money u/s 69 of the Act.

4. Learned CIT(A) has erred in law and on facts in not properly appreciating and considering various evidence and supporting documents available on record during the course of the assessment proceedings and not properly appreciating various facts and law in its proper perspective.

5. Learned CIT(A) has erred in law and on the facts in confirming the action of AO in charging interest u/s 234A/B/C/D.

6. Learned CIT(A) has erred in law and on the facts in confirming the action of AO in initiating penalty u/s 271(1)(c) of the Act which is wholly unsustainable in law and on facts of the case.

7. Your Appellant reserves the right to add, alter, amend and withdraw any of the above grounds of appeal.”

3. Brief facts of the case are that the assesse had filed her return of income for the AY 2014-15 declaring total income at Rs.5,62,494/- . The assessee had offered income of Rs.5,62,494/- under the head 'Income from other source' and tax was deducted by Anjanee Buildcon Pvt. Ltd. and Anjanee Build Tech under section 194H. In this case, information was received by the Department that the assessee had purchased Industrial Shed No. 22 in the project Kushal Industrial Park vide sale deed no.47/2014 dated 01.03.2014 and had paid Rs.25,00,000/- over and above the sale consideration. Therefore, the case was reopened u/s. 147 of the Act and notice u/s. 148 of the Act was issued on 31.03.2021 to the assesse. In response thereto, the assessee filed the return of income on 07.04.2021 declaring total income of Rs.5,62,490/-. Subsequently, notices u/s 143(2)/142(1) of the Act were issued from time to time, in response of which, the assessee filed her submissions/documents. On going through the submissions of the assessee alongwith the supporting documents, it was seen that during the year under consideration, the assessee was 10% partner in Vivek Buildcon, received commission income from Anjanee Buildcon Pvt. Ltd. and Anjanee Build Tech, had stitching & knitting income and received interest income. The assessee submitted that she paid an amount of Rs.14,61,000/- to M/s. Kushal Infrastructure Pvt. Ltd towards purchase of Industrial shed No. 22 in the project Kushal Industrial Park, however, she denied to have paid cash of Rs.25,00,000/- over and above the sale consideration. Regarding the source of funds of Rs.14.61 lakhs paid for purchase of property, she stated that Rs. 10,00,000/- was borrowed from the Bhagyodaya Coop. Bank Ltd., Rs.2,00,000/- was borrowed from Narendrasingh K. Pa