MANISH JAIN,JAIPUR vs. ITO, WARD-7(1), JAIPUR

ITA 1393/JPR/2025Status: DisposedITAT Jaipur08 September 2026AY 2022-239 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that the Revenue had no basis for the addition as Shri Sanjay Garg himself denied any transaction with the assessee. The Tribunal found that the entire case of the Revenue rested on surmises and conjectures without cogent evidence, especially since Shri Sanjay Garg's denial remained uncontroverted.

What were the facts?

The Assessing Officer (AO) made an addition of INR 1.20 crores to the assessee's income under Section 69A as unexplained money. This addition was based on information from an investigation wing suggesting the assessee paid cash to one Shri Sanjay Garg for foreign remittances. The AO confirmed this addition, which was also upheld by the CIT(A).

What were the issues?

Whether an addition under Section 69A can be sustained based on information from an investigation wing when the alleged recipient denies any transaction with the assessee, and whether principles of natural justice were violated by not confronting the assessee with evidence or allowing cross-examination.

Which sections of the Income-tax Act were involved?

Section 69A,Section 115BBE,Section 131(1A),Section 133(6)

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, JAIPUR BENCHES, “A” BENCH, JAIPUR

Hearing: 02.07.2026Pronounced: 08.09.2026

Per Annapurna Gupta, AM:- The present appeal has been filed by the assessee against the order passed by the National Faceless Appeal Centre (NFAC), Delhi (hereinafter referred to as “Ld. CIT(A)”), dated 14.08.2025 under P a g e | 2 Manish Jain Section250of the Income Tax Act, 1961 (hereinafter referred to as “the Act”).

2.

The grounds raised by the assessee read as under:-

1.

That on the facts and in circumstances of the case, the learned Assessing Officer as well as learned CIT(A) grossly erred in acting illegally on facts as well as in law, in assuming, presuming, on conjectures and surmises, in holding and making an addition of impugned amount of INR

The order continues below.

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