ITO 1(3)(1) AHMEDABAD, AHMEDABAD vs. NAVRANGRA GOVINORAMJ HUF, AHMEDABAD
In favour of the assessee: the Revenue's appeal was dismissed. From the AI summary of this appeal.
What did the Tribunal hold?
The Tribunal held that the Revenue's appeal was baseless as the assessee had advanced money through banking channels from disclosed sources and received a portion back through banking channels. The Tribunal found no merit in adding both the advanced and received amounts.
What were the facts?
The Assessing Officer (AO) received information that the assessee had received accommodation entries from Radhe Corporation. The AO reopened the case and added Rs. 3,52,34,740/- to the assessee's income. The assessee argued that they had advanced money to Radhe Corporation and received a portion back.
What were the issues?
Whether the addition made by the AO on account of alleged accommodation entries was justified when the assessee had demonstrated advancing funds and receiving them back through banking channels.
Which sections of the Income-tax Act were involved?
AI-generated summary — verify with the full judgment below
Income Tax Appellate Tribunal, “D” BENCH, AHMEDABAD
Before: Shri Sanjay Garg & Shri Narendra Prasad Sinha
IN THE INCOME TAX APPELLATE TRIBUNAL “D” BENCH, AHMEDABAD ] ] Before Shri Sanjay Garg, Judicial Member And Shri Narendra Prasad Sinha, Accountant Member आयकर अपील सं /ITA No.2506/Ahd/2025 िनधा�रण वष� /Assessment Year : 2013-14 बनाम ITO, v/s. Navrangra Govinoramj HUF, Ward-1(3)(1), A-21, Rushika Apartment Shahibaug, Ahmedabad Ahmedabad-380004 �थायी लेखा सं./PAN: AADHN3520M (अपीलाथ�/ Appellant) (�� यथ�/ Respondent) Assessee by : Ms. Astha Maniar, AR Revenue by : Shri Arvind Kumar Namdeo, Sr. DR सुनवाई की तारीख/Date of Hearing : 22/07/2026 घोषणा की तारीख /Date of Pronouncement: 30/07/2026 आदेश/O R D E R Per Sanjay Garg, Judicial Member: The present appeal has been preferred by the Revenue against the order of the Learned Commissioner of Income Tax (Appeals), National Faceless Appeal Centre (NFAC), Delhi [hereinafter referred to as ‘Ld. CIT(A)’] dated 17/10/2025 passed u/s 250 of the Income Tax Act, 1961 (hereinafter referred to as ‘the Act’) for the Assessment Year (AY) 2013- 14. 2. The Revenue has raised the following grounds of appeal:
“1. Whether the Ld. CIT(A) has erred in law and on facts in deleting the addition of Rs. 1,41,46,600/- (fund advanced by the assessee Rs.73,85,000/- and fund received of Rs.68,01,600/- from Radhe Corporation) without appreciating the facts of the case?
ITA No.2506/Ahd/2025 ITO vs. Navrangra Govinoramj HUF Asst.Year 2013-14 2 2. Whether the Ld. CIT(A) has failed to appreciate the fact that the additions were made on the basis of credible information from Investigation Wing that the assessee has made huge cash transaction with Radhe Corporation, which is the proprietorship of Shri Harish Purohit who was working under Sanjay Govindram Agrawal (also known as Sanjay Tibrewal or ST) who is into the business of providing accommodation entries, without any business activity? 3. The appellant craves leave to amend or alter any ground or add a new ground, which may be necessary. 4. It is, therefore, prayed that the order of Ld. CIT(A) may be set aside and that of the Assessing Officer be restored.” 3. The brief facts of the case are that the Assessing Officer (in short “the AO”) received information from Investigation Wing that the assessee had received certain accommodation entries amounting of Rs. 3,52,34,740/- from Radhe Corporation, run by one Shri Sanjay Govindram Agrawal alias Sanjay Tibrewal, who was engaged in providing accommodation entries. The case of the assessee was therefore reopened u/s 147 of the Income Tax Act.
During the assessment proceedings, the assessee denied having received any accommodation entry from the said concern. However, the AO rejected the contentions of the assessee and went with the report of the Investigation Wing and held that the assessee was beneficiary of the accommodation entry of Rs. 3,52,34,740/- and added the said amount into the income of the assessee.
During the appellate proceedings before the CIT(A), the assessee demonstrated that the assessee had not received any advances from the said Radhe Corporation or any other concern of Shri Sanjay Govindram Agrawal. It was further explained that, in fact, the assessee had given
ITA No.2506/Ahd/2025 ITO vs. Navrangra Govinoramj HUF Asst.Year 2013-14 3 short term loan/advances of Rs. 73.85 lakhs to said Radhe Corporation, out of which, an amount of Rs. 68,01,600/- was received back. The Ld. CIT(A) took note of the aforesaid fact and finding that there was no evidence of any amount received in any bank account of the assessee, except the aforesaid transaction. Further, the Ld. CIT(A) observed that it was not a case of obtaining of any accommodation entry rather, the assessee had received back the amount which was advanced by the assessee out of its disclosed sources. He, therefore, deleted the addition made by the AO.
Being aggrieved by the order of the CIT(A), the Revenue has come in appeal before us.
A perusal of the grounds of appeal of the Revenue would, in itself, reveal that the Revenue has admitted that the assessee had advanced a sum of Rs. 73,85,000/- to the said Radhe Corporation, out of which, the assessee received back an amount of Rs. 68,01,600/-. In the grounds of appeal, it has been pleaded that both the amount given and received should be added back into the income of the assessee because there is an Investigation Wing Report that the assessee has received accommodation entry. This type of plea by the Revenue is totally baseless, without application of mind and irresponsible, warranting exemplary costs. However, keeping judicial restraint, we at this stage are not imposing any costs but request to the concern authorities to be conscious while filing appeals before the ITAT. In this case, it is not the case of the Revenue that the amount advanced by the assessee of Rs.
ITA No.2506/Ahd/2025 ITO vs. Navrangra Govinoramj HUF Asst.Year 2013-14 4 73.85 lakh was out of its any unexplained sources of income. The assessee admittedly had advanced the amount through banking channel out of his disclosed sources/bank account. Thereafter, the assessee received back the amount of Rs. 68,01,600/- through banking channel. We fail to understand how the amount given by the assessee and thereafter received back by the assessee should be summed up for making the addition, as has been pleaded by the Revenue. There is no merit in the appeal of the Revenue and the same is hereby dismissed.
In the result, appeal of the Revenue is hereby dismissed.
Order pronounced in the Open Court on 30/07/2026.
Sd/- Sd/- (Narendra Prasad Sinha) (Sanjay Garg) Accountant Member Judicial Member अहमदाबाद/Ahmedabad, िदनांक/Dated 30/07/2025 Tanmay, Sr. P.S. TRUE COPY आदेश की �ितिलिप अ�ेिषत/Copy of the Order forwarded to : 1. अपीलाथ� / The Appellant 2. ��थ� / The Respondent. 3. संबंिधत आयकर आयु� / Concerned CIT 4. आयकर आयु� अपील ( ) / The CIT(A)-(NFAC) 5. िवभागीय �ितिनिध आयकर अपीलीय अिधकरण अहमदाबाद /DR,ITAT, Ahmedabad. , , 6. गाड� फाईल / Guard file. आदेशानुसार/ BY ORDER,
सहायक पंजीकार (Asstt. Registrar) आयकर अपीलीय अिधकरण, ITAT, Ahmedabad
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