SHRI SADGURU DEVELOPERS,SHAPAR, RAJKOT vs. THE DEPUTY/ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE - 1, RAJKOT

ITA 194/RJT/2025Status: DisposedITAT Rajkot08 September 2026AY 2022-237 pages
AI SummaryPartly Allowed

What did the Tribunal hold?

The Tribunal held that the profit element embedded in the on-money receipts should be estimated at 10%, considering the facts and previous judicial precedents. This rate was deemed to meet the ends of justice.

What were the facts?

During a search, unaccounted cash receipts and expenses related to a real estate project were discovered. The Assessing Officer estimated profit on these unaccounted receipts at 40%, while the CIT(A) reduced it to 16%.

What were the issues?

The primary issue was the correct estimation of the profit element embedded in unaccounted on-money receipts. The Tribunal also considered the year-wise taxability of these receipts.

Which sections of the Income-tax Act were involved?

Section 147,Section 148,Section 143(2),Section 142(1),Section 145(3)

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, Rajkot Bench, Rajkot

Before: Dr. Arjun Lal Saini & Shri Sonjoy Sarma

For Appellant: Shri Vimal Desai, Ld. AR
For Respondent: Shri Ganesh Iyer, Ld. Sr. DR
Hearing: 25/08/2026Pronounced: 08/09/2026

Per, Shri Sonjoy Sarma, JM: Captioned these appeals in ITA No. 191/RJT/2025 is filed by the assessee for Assessment Year (A.Υ.) 2019-20, ITA No. 192/RJT/2025 for A.Y. 2020-21, ITA No. 193/RJT/2025 for A.Y. 2021-22, and ITA No. 194/RJT/2025 for A.Y. 2022- 23. All four appeals are directed against the common appellate order dated 21.01.2025 passed by the

The order continues below.

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