SHETAL RAMESHBHAI MODI,ANKLESHWAR vs. ITO WARD 2(1), BHARUCH

ITA 502/SRT/2026Status: DisposedITAT Surat10 August 2026AY 2020-217 pages
AI SummaryPartly Allowed

What did the Tribunal hold?

The Tribunal noted that the assessee is a small trader dealing in a cash-oriented business. It was held that the Assessing Officer cannot make additions for both expenditure and estimated profit on the same item, as it would lead to double taxation. Therefore, the addition confirmed by the CIT(A) was deleted.

What were the facts?

During a search action, unaccounted purchases of Rs. 9,80,900/- were found to have been made by the assessee from a fireworks trading group. The Assessing Officer added Rs. 6,05,220/- as unexplained expenditure for the purchase of crackers.

What were the issues?

Whether the addition for unexplained expenditure on the purchase of crackers is sustainable when the assessee has offered business income on the sale of such crackers, and whether making additions for both expenditure and estimated profit on the same item is permissible.

Which sections of the Income-tax Act were involved?

Section 69C,Section 115BBE,Section 132,Section 147,Section 148A,Section 148

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, “SMC”

Before: Dr. Arjun Lal Saini

For Appellant: Shri Rasesh Shah, CA
For Respondent: Shri Ajay Uke, Sr. DR
Hearing: 18/05/2026

Per, Dr. Arjun Lal Saini, AM: Captioned appeal filed by the assessee, pertaining to Assessment Year 2020- 21, is directed against the order passed under section 250 of the Income Tax Act, 1961 (hereinafter referred to as “the Act”) by Commissioner of Income-tax (Appeals), National Faceless Appeal Centre (NFAC) Delhi, dated 14.01.2026, which in turn arises out of an order passed by the Assessing Officer u/s 147 of the Act, on 26.03.2025. 2. At the outset, Ld. Counsel for the assessee informs the Bench that assessee does not wish to press Ground No

The order continues below.

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