KAUSHIK JENTIBHAI RATHOD,VERAVAL vs. ITO, WARD-4, VERAVAL, VERAVAL

ITA 940/RJT/2026Status: DisposedITAT Rajkot09 September 2026AY 2019-2011 pages
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What did the Tribunal hold?

The Tribunal held that additions cannot be made solely based on 'dump documents' like unsigned and undated excel sheets without corroborative evidence. Such documents lack evidentiary value and cannot form the basis for assessment.

What were the facts?

The Assessing Officer (AO) made additions to the income of several assessees based on an unsigned, undated, and editable excel sheet found at a third party's premises. The assessees' appeals against these additions were confirmed by the CIT(A).

What were the issues?

Whether additions can be made based on unsigned and undated excel sheets (dump documents) without corroborative evidence. Whether proceedings initiated under Section 147 are valid when based on such documents.

Which sections of the Income-tax Act were involved?

Section 147,Section 69A,Section 115BBE

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Heard together (3 matters)

ITA No. 940/RJT/2026
ITA No. 937/RJT/2026
ITA No. 782/RJT/2026

Read from the judgment's own cause title. This page is filed under one of them.

आयकर अपीलीय अिधकरण, राजकोट "यायपीठ, राजकोट। In The Income Tax Appellate Tribunal, “SMC” Rajkot Bench, Rajkot Before Dr. Arjun Lal Saini, Accountant Member आयकरअपीलसं./ITA No. 940/RJT/2026 [ "नधा"रणवष"/Assessment Year: 2019-20 ] Kaushik Jentibhai Rathod The Income-tax Officer, Ward-4, "ायीलेखासं./जीआइआरसं./PAN/GIR No.: CIOPR7808H (अपीलाथ"/Assessee) (""यथ"/Respondent)

आयकरअपीलसं./ITA No. 937/RJT/2026 [ "नधा"रणवष"/Assessment Year: 2019-20 ] Rasikbhai Popatbhai Kathiriya The Income-tax Officer, Ward- Akash Meera Park, St. No.1, Vs. 2(1)(1), Rajkot Kuvadva Road, Opp. L P Park, Aayakar Bhavan, Racecourse Ring Rajkot Gujarat 360003 Road, Rajkot Gujarat 360005 "ायीलेखासं./जीआइआरसं./PAN/GIR No.: AQRPK5434B (अपीलाथ"/Assessee) (""यथ"/Respondent)

आयकरअपीलसं./ITA No. 782/RJT/2026 [ "नधा"रणवष"/Assessment Year: 2018-19 ] Shri Chirag Narendrabhai Bakhada The Income-tax Office, Ward- Block No.41/764, Guj Gramya Nir Vs. 1(1)(1), Rajkot Board, Behind SNK School, Aayakar Bhavan, Race Course University Road, Ring Road, Rajkot Gujarat 360005 Rajkot Gujarat 360005 "ायी

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