LT. SH. PRADEEP KUMAR JAIN THROUGH SUNITA JAIN L/H SMT,TONK vs. THE INCOME TAX OFFICER, WARD TONK

ITA 191/JPR/2026Status: DisposedITAT Jaipur16 September 2026AY 2020-218 pages
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What did the Tribunal hold?

The Tribunal held that the assessee's admission, corroborated by his court petition, established the advance. However, the declared borewell income and gifts explained a significant portion of the advance, preventing double taxation. The remaining unexplained amount was deemed income.

What were the facts?

The assessee admitted to advancing Rs 30,00,000 of his unaccounted income as a cash loan. He later declared Rs 18,02,500 as borewell income and Rs 7,75,000 as gifts in his return. The Assessing Officer added the entire Rs 30,00,000 under Section 69A, which was upheld by the CIT(A).

What were the issues?

Whether the entire Rs 30,00,000 advanced as a loan constituted unexplained income under Section 69A, and if the declared income and gifts could be considered as the source of the advance, thereby avoiding double taxation.

Which sections of the Income-tax Act were involved?

Section 69A,Section 115BBE,Section 131,Section 147,Section 250

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), National Faceless Appeal Cen- tre, Delhi [hereinafter referred to as “the learned CIT(A)”] dated 24.11.2025 passed under section 250 of the Income Tax Act, 1961 (herei- nafter referred to as “the Act”) arising out of the assessment order dated 24.03.2025 passed by the Assessing Officer (hereinafter referred to as “the AO”) under section 147 of the Act for the assessment year 2020-21. 2. The grounds of appeal raised by the Assessee before us in the memoran- dum of appeal in

The order continues below.

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