Mumbai’s Income Tax Appellate Tribunal ordered a fresh review on October 29, 2026, of the Rs 2.59 crore tax demand against Kaushik Narottam Soni. The case concerns a Rs 1.5 crore NRI fixed deposit held jointly with his father, which Soni says his father funded and owned.
The Financial Express first reported the tribunal’s remand. The order returns the matter to the Assessing Officer to check bank documents submitted by Soni.
It does not cancel the addition or settle ownership. The dispute concerns assessment year 2019-20, when Soni was a non-resident Indian.
The tribunal said the documents “go to the heart of the dispute.” The officer must examine them before the tax department reaches a conclusion.
The officer must verify records naming Soni’s father as first holder
The remand calls for examination of two records: a statement showing the source of the deposit and a bank certificate identifying Narottam Odhavji Soni as its first holder. The tribunal’s instruction is to verify those documents, not to accept their contents without review.
Soni’s position is that his father was the beneficial owner and his own name appeared only as a joint or third holder. He said the bank added him as a joint holder “for administrative convenience and to ensure the smooth transfer of assets.”
The son’s name on the account and the source of the money are separate parts of his claim. The tribunal has sent the documents back for examination but made no final finding on either ownership or the tax treatment of the funds.
The department’s reassessment relied on the deposit’s appearance in Soni’s name
The Income Tax Department received information through its Insight Portal about financial transactions linked to Soni. It reopened his assessment under Section 147 of the Income-tax Act and asked him to explain the money invested in the deposit recorded in his name.
Soni did not provide supporting bank records during reassessment. The Assessing Officer also sought information from HDFC Bank under Section 133(6), but the bank did not respond.
With no documents then establishing the source or ownership, the officer treated the full Rs 1.5 crore as Soni’s unexplained investment under Section 69 of the Act. The amount was added to his income.
The Dispute Resolution Panel upheld the addition. A final assessment order followed on December 10, 2025.
The resulting demand totals Rs 2.59 crore, including tax arising from the addition, interest and other applicable levies. The tribunal has returned the case for the officer to consider evidence that was not submitted during the reassessment proceedings.
Soni says his father funded the deposit from an NRE account
Soni argued before the tribunal that joint account status did not establish who supplied the investment money. He said his father created the deposit using funds from a Non-Resident External (NRE) account.
His father, Narottam Odhavji Soni, was also a non-resident. Soni argued that the funds represented foreign income and were not taxable in India because both father and son were non-residents during the relevant period.
Those are the taxpayer’s arguments, not findings made by the tribunal. Its direction requires the Assessing Officer to assess the bank records before reaching a conclusion.
The Rs 2.59 crore figure includes the tax associated with the addition, interest and other applicable levies. The order did not delete the addition, and it did not issue a final ruling on who owned the deposit.
The Assessing Officer must now verify the source statement and the certificate naming Soni’s father as first holder. The fresh review is the next step identified in the tribunal’s order.
