Taxpayer ignored 4 income-tax notices and faced ₹1.55 crore additions: What Delhi ITAT ruled and why it matters

Delhi ITAT has given a taxpayer another chance to contest ₹1.55 crore in income additions after she failed to respond to four appellate notices. The tribunal said the CIT(A) cannot dismiss an appeal without examining the issues on merits and passing a reasoned order. 

A taxpayer who failed to respond to multiple income-tax notices was facing additions of nearly ₹1.55 crore to her income. In Jusbinder Kour vs ITO, ITA No. 4452/Del/2026, the Delhi bench of the Income Tax Appellate Tribunal (ITAT) has now ruled that the appellate authority cannot simply dismiss her appeal without examining the issues on merits and giving reasons.

Kour had filed her income-tax return on 4 January 2021, declaring total income of ₹10.41 lakh, comprising salary income. The tax department subsequently received information about ₹21.90 lakh in cash deposits and the purchase of an immovable property for ₹74 lakh. The assessing officer (AO) sought an explanation, but Kour did not respond.

The AO then initiated reassessment proceedings and issued notices under sections 148, 142(1) and 144 of the Income-tax Act, along with show-cause notices. The taxpayer did not respond to these either. The AO subsequently sought information directly from Punjab and Sind Bank and Union Bank of India under section 133(6).

Tax department made ₹1.55 crore additions

Information received from the banks showed cash deposits and other credits totalling ₹80.94 lakh, excluding a ₹34 lakh loan received by Kour. Since she had not explained the nature and source of the deposits, the AO treated ₹80.94 lakh as unexplained money under section 69A and added it to her income.

The AO also made a separate ₹74 lakh addition under section 69 for the property purchase because Kour had not explained the source of the investment.

Together, the two additions amounted to ₹1.549 crore.