PANKAJ BOHRA,IMPHAL vs. DCIT, CENTRAL CIRCLE-1, GUWAHATI, GUWAHATIT

ITA 386/GTY/2025Status: DisposedITAT Guwahati20 August 2026AY 2022-2332 pages
AI SummaryPartly Allowed

What did the Tribunal hold?

The Tribunal upheld the addition of the seized cash under section 69A but reduced the amount to ₹19,97,605/-, treating it as income from undisclosed sources. Various procedural grounds raised by the assessee were dismissed.

What were the facts?

The assessee's income was reopened after cash of ₹50,00,000/- was seized. Initially, the assessee claimed the cash belonged to his employers, then to sales from a face mask business. The Assessing Officer rejected this, deeming it unexplained money.

What were the issues?

Whether the addition of seized cash was justified, and whether the assessment proceedings were conducted in accordance with law and principles of natural justice.

Which sections of the Income-tax Act were involved?

Section 147,Section 156,Section 44AD,Section 69A,Section 40A(3),Section 115BBE,Section 143(3),Section 292B

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, GUWAHATI ‘DB’ BENCH AT KOLKATA

Before: SHRI YOGESH KUMAR US & SHRI RAKESH MISHRA

PER RAKESH MISHRA, ACCOUNTANT MEMBER:

This appeal filed by the assessee is against the order of the Commissioner of Income Tax (Appeals)-Central NER, Guwahati [hereinafter referred to as Ld. 'CIT(A)'] passed u/s 250 of the Income Tax Act, 1961 (hereinafter referred to as ‘the Act’) for AY 2022-23 dated 25.09.2025. 2. The assessee is in appeal before the Tribunal raising the following grounds of appeal:

"

1.

For that the learned CIT(A) ought to have hold that the order of assessment dated 04.06.2024 passed under section 147 of the Income-tax Act, 1

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 →