JANAKSINH JAYVANTSINH SARVAIYA,VADODARA vs. INCOME TAX OFFICER, WARD 4(1)(7), VADODARA, VADODARA

ITA 2575/AHD/2025Status: DisposedITAT Ahmedabad21 September 2026AY 2010-1121 pages
AI SummaryPartly Allowed

What did the Tribunal hold?

The Tribunal held that the CBDT circular on jewellery limits should be applied in spirit even if the search was by ACB, and that cash deposits from a genuine land sale agreement were not unexplained. However, the reassessment proceedings were not quashed.

What were the facts?

The assessee appealed against an order confirming additions made under Section 69A for unexplained cash and jewellery. The reassessment proceedings were challenged on grounds of invalid initiation and reliance on ACB search findings.

What were the issues?

The key issues were the validity of reassessment proceedings initiated under Section 147 and whether additions for unexplained cash and jewellery were justified, particularly concerning the applicability of CBDT circulars and the genuineness of land sale transactions.

Which sections of the Income-tax Act were involved?

Section 147,Section 148,Section 151,Section 132A,Section 153A,Section 69A,Section 250

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, AHMEDABAD “A” BENCH

Before: Shri Narendra Prasad Sinha & Shri Tapas Ram Misra

For Appellant: Shri Virat Bhavsar, CA
For Respondent: Shri Amit Pratap Singh, Sr. D.R

PER TAPAS RAM MISRA, JUDICIAL MEMBER:

The present appeal has been filed by the Assessee against the order of the Ld. Commissioner of Income Tax (Appeals), National Faceless Appeal Centre (hereinafter referred to as “NFAC”), Delhi (hereinafter referred to as “CIT(A)”), dated 27.10.2025 passed under Section 250 of the Income Tax Act, 1961 (hereinafter referred to as the “Act”) and relates to Assessment Year (A.Y.) 2010-11. I.T.A No. 2575/Ahd/2025 A.Y. 2010-11

2.

The assessee has raised the following grounds of appeal: All the grounds of appeal in this appeal are mutually exclusive and w

The order continues below.

Read the full judgment

A free account opens 10 full judgments a month. Re-reading one you have already opened does not count again.

Create a free accountSign in

See plans and prices

The summary, the parties, the sections and the citations above are open to everyone and always will be. Only the text of the order and the PDF are metered.

More judgments on Section 147

All 49,210 judgments and leading authorities on Section 147 →

Recent GST High Court judgments

Search GST case law →