MANOJ KUMAR GUPTA,JAIPUR vs. ACIT, CENTRAL CIRCLE 3, JAIPUR

ITA 1478/JPR/2025Status: DisposedITAT Jaipur16 September 2026AY 2019-208 pages
AI SummaryAllowed

What were the facts?

During a search, Rs. 16,00,000 cash was seized from the assessee's residence. The Assessing Officer treated this as unexplained money under Section 69A and taxed it under Section 115BBE. The assessee claimed the cash belonged to his employer company and was kept for safe custody.

What did the Tribunal hold?

The Tribunal held that the assessee had rebutted the presumption of ownership arising from possession. The explanation was offered early, supported by the company's cash book and audited accounts, and the Revenue failed to disprove it.

What were the issues?

Whether the cash found in the assessee's possession, claimed to belong to his employer, could be treated as unexplained money under Section 69A. Whether the assessment order was valid without a proper notice under Section 143(2).

Which sections of the Income-tax Act were involved?

Section 69A,Section 115BBE,Section 143(2),Section 153B(1)(b),Section 132(4)

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, ‘B’ BENCH, JAIPUR

Before: Shri T.R. Senthil Kumar & Shri Prakash

PER : PRAKASH, ACCOUNTANT MEMBER:-

1.

This appeal by the Assessee is directed against the order of the learned Commissioner of Income Tax (Appeals)‑4, Jaipur [hereinafter referred to as “the learned CIT(A)”] dated 29.09.2025 passed under section 250 of the Income Tax Act, 1961 (hereinafter referred to as “the Act”), arising out of the assessment order dated 22.07.2021 passed by the Assessing Officer (hereinafter referred to as “the AO”) under section 143(3) read with section 153B(1)(b) of the Act for the assessment year 2019‑20. 2. The grounds of appeal raised by the Assessee before us in the memoran- dum of appeal in Form No. 36 read as under:

I.T.A

The order continues below.

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