ACIT CENTRAL CIRCLE 1 RAIPUR, RAIPUR vs. WALLFORT PROPERTIES PVT LTDQ, RAIPUR

ITA 676/RPR/2025Status: DisposedITAT Raipur21 September 2026AY 2023-2418 pages
AI SummaryDismissed

What did the Tribunal hold?

The Tribunal held that only the profit embedded in 'on-money' receipts is taxable, not the entire amount, as a portion is typically used for unaccounted expenses. Regarding bogus expenditure, the Tribunal noted that the Department had accepted similar transactions in a prior assessment year without change in facts.

What were the facts?

During a search, the Revenue found evidence of 'on-money' transactions in real estate sales. The Assessing Officer (AO) treated the entire 'on-money' as income, while the Commissioner (Appeals) restricted the addition to the profit element. The AO also disallowed purchases and contract payments treated as bogus expenditure.

What were the issues?

Whether the entire 'on-money' received by the assessee is taxable as income, or only the profit element. Whether the disallowance of purchases and contract payments as bogus expenditure is justified when similar transactions were accepted in a prior year.

Which sections of the Income-tax Act were involved?

Section 132,Section 147,Section 143(3),Section 139(1),Section 127,Section 148,Section 270A

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, RAIPUR BENCH, “DB” RAIPUR

Before: SHRI R.K PANDA & SHRI PARTHA SARATHI CHAUDHURY

For Appellant: Shri Amit Maloo Jain, Advocate
For Respondent: Shri Rituparna Namdeo, CIT-DR
Hearing: 05.08.2026Pronounced: 21.09.2026

PER PARTHA SARATHI CHAUDHURY, JM: The captioned appeals preferred by the Revenue emanates from the respective orders of the Ld.CIT(Appeals), Raipur-3 dated 19.08.2025 for the assessment year 2020-21 & 2023-24 as per the grounds of appeal on record.

2.

At the very outset, parties herein conceded that the facts and circumstances and issues involved in both these appeals are absolutel

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 132

All 14,598 judgments and leading authorities on Section 132 →

Recent GST High Court judgments

Search GST case law →