VIJYABEN RAMNIKBHAI TRAMBADIYA,JUNAGADH vs. ITO, WARD-2, JUNAGADH, INCOME TAX OFFICE

ITA 568/RJT/2026Status: DisposedITAT Rajkot21 September 2026AY 2012-201310 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that the addition was based on an unsigned excel sheet found during a search at a third party's premises, lacking any nexus with the assessee or corroborative evidence. Therefore, the addition was deleted.

What were the facts?

The assessee purchased a flat for Rs. 4,95,000, but a seized diary indicated an 'on-money' payment of Rs. 4,20,000. The Assessing Officer added this amount as unexplained investment, which was confirmed by the CIT(A).

What were the issues?

Whether additions based on unsigned documents found during a third-party search, without corroborative evidence linking them to the assessee, are sustainable.

Which sections of the Income-tax Act were involved?

Section 147,Section 148,Section 143(3),Section 69B,Section 132(4A),Section 153C

AI-generated summary — verify with the full judgment below

Cause title — parties, addresses and appearances
आयकर अपीलीय अिधकरण, राजकोट "यायपीठ, राजकोट। In The Income Tax Appellate Tribunal, Rajkot Bench, Rajkot Before Dr. Arjun Lal Saini, Accountant Member And Shri Sonjoy Sarma, Judicial Member आयकरअपीलसं./ITA No. 568/Rjt/2026 [ "नधा"रण वष"/Assessment Year: 2012-13 ] Vijyaben Ramnikbhai Trambadiya, ITO WD 2, JND M. N. Manvar & Co., Chartered Bhootnath Chamber, Vs. Accountants 504, Star Plaza, Nr. Junagadh, Gujarat, 362001 Circuit House, Phulchhab Chowk, Rajkot (Gujarat) 360001 "थायीलेखासं./जीआइआरसं./PAN/GIR No.: BSXPT8569H (अपीलाथ"/Assessee) (""यथ"/Respondent) Assessee by : M. N. Manvar, Ld. AR Respondent by : Shri Ganesh Iyer, Ld. Sr. DR Date of Hearing : 06/07/2026 21/09/2026 Date of Pronouncement :

:: ORDER :: Dr. Arjun Lal Saini, AM: Captioned appeal filed by the assessee, pertaining to assessment year (AY) 2012-13, is directed against the order under section 250 of the Income- tax Act, 1961 (hereinafter referred to as ‘the Act’) passed by the National Faceless Appeal Centre (NAC) Delhi/Commissioner of Income-tax (Appeals) [in short ‘NFAC/Ld.CIT(A)’], dated 27.02.2026, which in turn arises out of an assessment order passed by the Assessing Officer u/s 143(3) r.w.s. 147 of the Act, da

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 →