SOVANI DEVI PUROHIT,JALORE vs. DCIT CENTRAL CIRCLE 2, JODHPUR

ITA 1056/JODH/2026Status: DisposedITAT Jodhpur19 August 2026AY 2018-20194 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that additions cannot be made solely based on materials found in a third party's search and statements from that third party, especially when the assessee denies paying on-money and no other corroborative evidence exists.

What were the facts?

During a search operation, information was found suggesting the assessee paid on-money for shop rooms. The Assessing Officer made additions based on this information and statements from third parties, as the assessee allegedly failed to provide evidence.

What were the issues?

Whether additions can be made on account of alleged on-money payment based on third-party evidence without corroboration, when the assessee denies such payment.

Which sections of the Income-tax Act were involved?

Section 132(4)

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, JODHPUR BENCH, JODHPUR

Before: SHRI SAKTIJIT DEY, HON’BLE & SHRI MAKARAND VASANT MAHADEOKAR, HON’BLE

For Appellant: Shri Bharat Kumar Rajpurohit CA
For Respondent: Ms. Shivani Bansal CIT-DR

Per: Shri Saktijit Dey; V.P. :

The aforesaid appeals, relating to the same assessee, arise out of separate orders of learned Commissioner of Income Tax (Appeals) [in short, ‘ld. CIT(A)’], Jaipur, pertaining to Assessment Years 2017-18, 2018-19, and 2019-20. 2. The common dispute arising on merits in all these appeals relates to addition on account of on money payment for purchase of shop rooms.

3.

Briefly the facts common in all these appeals are, the assessee is a resident individual. In course of search and seizure operation conducted in case of Rubberwala Group and others on 17-03-2021, it wa

The order continues below.

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