DONKALA CHENCHU NARASIMHA RAO,NELLORE vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, GUNTUR, GUNTUR

ITA 298/VIZ/2026Status: DisposedITAT Visakhapatnam09 September 2026AY 2020-2115 pages
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What did the Tribunal hold?

The Tribunal held that additions cannot be made solely on the basis of loose sheets found during a survey without corroborative evidence. The Tribunal also upheld the addition for the difference between physical and book stock due to lack of explanation from the assessee.

What were the facts?

During a survey, incriminating material was found, leading the AO to make additions for unexplained loans and investments. The assessee claimed the material was unsubstantiated and denied making on-money payments for property purchases.

What were the issues?

Whether additions can be made based on unsubstantiated material found during a survey, and whether the assessee provided sufficient explanation for stock differences.

Which sections of the Income-tax Act were involved?

Section 69,Section 68

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Income Tax Appellate Tribunal, VISAKHAPATNAM BENCH, VISAKHAPATNAM

Before: SHRI VIJAY PAL RAO, HON’BLE & SHRI MANJUNATHA G, HON’BLE

PER MANJUNATHA G, AM This appeal is filed by the Assessee against the order of Learned Commissioner of Income Tax (Appeals)-3, Visakhapatnam [hereinafter in short “Ld. CIT(A)”] vide DIN: ITBA/APL/S/250/2025-26/1084519345(1) dated 07.01.2026 for the Assessment Year 2020-21. ITA 298/VIZ/2026 DONKALA CHENCHU

The order continues below.

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