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Mismatch in Form 26AS Led to ₹15.43 lakh Addition: ITAT Remands Matter to AO for Verification [Read Order]

During appellate proceedings, the assessee furnished reconciliation details, prompting the Tribunal to direct fresh adjudication and ensure adequate opportunity of hearing.

Mismatch in Form 26AS Led to ₹15.43 lakh Addition: ITAT Remands Matter to AO for Verification [Read Order]
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The Ahmedabad Bench of Income Tax Appellate Tribunal ( ITAT ) remanded the matter to the Assessing Officer (AO) for verification, after noting that an addition of ₹15.43 lakh was made due to mismatch in Form 26AS. Detective And Security Services,appellant-assessee, had filed its return declaring income of Rs. 97,73,900. During assessment, the Assessing Officer noticed a mismatch...


The Ahmedabad Bench of Income Tax Appellate Tribunal ( ITAT ) remanded the matter to the Assessing Officer (AO) for verification, after noting that an addition of ₹15.43 lakh was made due to mismatch in Form 26AS.

Detective And Security Services,appellant-assessee, had filed its return declaring income of Rs. 97,73,900. During assessment, the Assessing Officer noticed a mismatch of Rs. 15,43,980 in the 26AS details related to four parties and believed it to be unexplained money. A notice under Section 148 was issued on 30-06-2022. After considering the assessee’s reply, the AO passed the order under Sections 147/144B on 11-05-2023, assessing income at Rs. 1,13,17,880 by adding Rs. 15,43,980.

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Aggrieved by the assessment order, the assessee filed an appeal before the Commissioner of Income Tax (Appeals)[CIT(A)], who dismissed the appeal.

The assessee counsel informed that the reconciliation details for the variation in Form 26AS, as noted in the assessment order, were now available. Accordingly, a request was made to remand the matter to the AO for fresh consideration. The departmental representative, however, supported the assessment order and the CIT(A)’s decision.

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The two member bench comprising Dr.BRR Kumar (Vice President) and Suchitra Kamble (Judicial Member) considered the submissions of both sides and examined the material on record.

Since the assessee had provided reconciliation details at this stage, the tribunal found it necessary to send the matter back to the AO for proper verification and adjudication of the differences reflected in Form 26AS. It also directed that the assessee be given an adequate opportunity of hearing.

The appeal was treated as partly allowed for statistical purposes.

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