SADBHAVNA ENTERPRISE,VAPI,GUJARAT vs. ITO WARD 7,VAPI, VAPI,GUJARAT

ITA 182/SRT/2026Status: DisposedITAT Surat10 September 2026AY 2020-214 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that the AO and CIT(A) failed to consider that the amounts in question were unsecured loans from M/s. VRB Capital Services India Private Limited, not purchases. The assessee provided bank statements and confirmation from the creditor, which indicated the nature of the transactions as loans and interest, with TDS deducted.

What were the facts?

The assessee's case was reopened based on information from a search action related to illegal online betting activities, where accommodation entries were used to route cash. The Assessing Officer (AO) added Rs. 1,35,000/- for AY 2019-20 and Rs. 12,38,393/- for AY 2020-21 on account of accommodation entries and disallowance of interest, respectively. The CIT(A) upheld these additions.

What were the issues?

Whether the additions made by the AO and confirmed by the CIT(A) were based on factual evidence, considering the nature of transactions as unsecured loans rather than accommodation entries.

Which sections of the Income-tax Act were involved?

Section 147,Section 148A,Section 148,Section 144,Section 144B

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, SURAT BENCH, SURAT

Before: MS. SUCHITRA KAMBLE & SHRI B.M. BIYANI

For Appellant: Shri Arjav Vidani, CA
For Respondent: Shri Ashish Kumar, Sr. DR
Hearing: 24.06.2026Pronounced: 10.09.2026

PER : SUCHITRA KAMBLE, J M: These appeals filed by the assessee are against the order passed by the Learned Commissioner of Income Tax, Appeal, National Faceless Appeal Centre (NFAC) [in short “CIT(A)”] dated 17.12.2025 for the Assessment Years (in short “AY”) 2019-20 & 2020-21. 2. Firstly, we are taking up ITA No.181/SRT/2026 pertaining to A.Y. 2019-

20.3.

The assessee has raised the following grounds of appeal:

“1. Learned CIT(A) has erred in law and fact by confirming addition of Rs.1,35,000/- made by learned assessing officer on account of accommodation entries.

ITA Nos.181 & 182/SRT/2026 Sadbhavna Enterprise

2.

Your appellant prays and with your Honour's pre per

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 →