BHAGWANDAS PARVANI,NADIAD vs. INCOME TAX OFFICE, NADIAD

ITA 674/AHD/2026Status: DisposedITAT Ahmedabad14 September 2026AY 2020-217 pages
AI SummaryPartly Allowed

What did the Tribunal hold?

The Tribunal held that in a presumptive taxation scheme under Section 44AD, the disclosed turnover encompasses all business receipts, and the net profit rate accounts for all expenses. Therefore, the addition of purchases as unexplained expenditure was deleted.

What were the facts?

The assessee, who opted for presumptive taxation under Section 44AD, had purchases of ₹1,80,000 recorded in his cash book. The Assessing Officer initiated reassessment proceedings and added this amount as unexplained expenditure under Section 69C, which was upheld by the CIT(A) for non-compliance.

What were the issues?

Whether purchases recorded in the cash book can be treated as unexplained expenditure under Section 69C for an assessee opting for presumptive taxation under Section 44AD. Whether reassessment proceedings were validly initiated.

Which sections of the Income-tax Act were involved?

Section 147,Section 144,Section 69C,Section 44AD,Section 115BBE,Section 234A,Section 234B,Section 274,Section 271AAC

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, SMC” BENCH, AHMEDABAD

Per Rahul Chaudhary, Judicial Member:

1.

The present appeal has been preferred by the Assessee against the Order, dated 23/09/2025, passed by the National Faceless Appeal Centre (NFAC), Delhi [hereinafter referred to as the ‘CIT(A)’] whereby the Learned CIT(A) had dismissed the appeal against the Assessment Order, dated 27/03/2025, passed under Section 147 read with Section 144 of the Income Act, 1961 [hereinafter referred to as ‘the Act’] for the Assessment Year 2020-2021. 2. There is a delay of 93 days in filing the present appeal. We have taken into consideration the explanation offered by the Assessee for delay in filing the present appeal. We are of the view that the Assessee wa

The order continues below.

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