DCIT, CENTRAL CIRCLE-30, NEW DELHI vs. SHALIMAR CORP. LTD., MUMBAI

ITA 2854/DEL/2022Status: DisposedITAT Delhi31 July 2025AY 2015-16Bench: SHRI SATBEER SINGH GODARA (Judicial Member), SHRI S. RIFAUR RAHMAN (Accountant Member)10 pages
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What did the Tribunal hold?

The Tribunal held that adding the Rs. 101 crores on-money admission over and above the special auditor's quantification was a double addition and directed its deletion. Additions related to unsecured loans and unexplained investments were to be treated as business turnover and assessed at 20%.

What were the facts?

During a search, incriminating documents indicated on-money payments in real estate transactions, leading to Section 153A proceedings. The assessee admitted to Rs. 101 crores of on-money payments, which was later quantified by a special auditor. The Assessing Officer added this amount again, leading to disputes.

What were the issues?

Whether the on-money admission during search could be added again after being included in the special auditor's quantification. How to assess unsecured loans and unexplained investments derived from on-money components.

Which sections of the Income-tax Act were involved?

Section 153A,Section 143(3),Section 132(4),Section 68,Section 69,Section 40A(3)

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Cases cited in this judgment(1)Show list

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Income Tax Appellate Tribunal, DELHI BENCH: ‘G’ NEW DELHI

Before: SHRI SATBEER SINGH GODARA & SHRI S. RIFAUR RAHMAN

Hearing: 17.07.2025Pronounced: 31.07.2025

Heard together (2 matters)

ITA Nos.2502/Del/2023
ITA Nos.2360/Del/2023

Read from the judgment's own cause title. This page is filed under one of them.

PER BENCH: The instant batch of nine appeals pertain to the same

assessee, namely, M/s. Shalimar Corp Ltd. All other relevant

details stand tabula

The order continues below.

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