HITESHKUMAR BABULAL RAMANI,CITY LIGHT, SURAT vs. ACIT, CENTRAL CIRCLE-4, SURAT, MAJURA GATE, SURAT

ITA 460/SRT/2024Status: DisposedITAT Surat27 July 2026AY 2014-157 pages
AI SummaryDismissed

What did the Tribunal hold?

The Tribunal upheld the CIT(A)'s order, finding the 10% profit estimation on undisclosed bank account transactions reasonable. The addition based on the WhatsApp image was deleted by the CIT(A) due to lack of corroboration and link to the assessee.

What were the facts?

The assessee, engaged in real estate, had an undisclosed bank account used for transactions. The Assessing Officer added the entire credit as unexplained income and also added a sum based on a WhatsApp image. The CIT(A) partly allowed the appeal, sustaining an addition of 10% profit on the undisclosed bank account credits and deleting the addition based on the WhatsApp image.

What were the issues?

Whether the entire credit in an undisclosed bank account can be added as income, or only the profit element. Whether an addition based on a WhatsApp image without corroboration is sustainable.

Which sections of the Income-tax Act were involved?

Section 68,Section 69A,Section 147,Section 148,Section 133A,Section 131,Section 142(1),Section 139,Section 115BBE

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, SURAT BENCH, SURAT

Before: Shri T. R. Senthil Kumar & Shri Ratnesh Nandan Sahay

For Appellant: Shri Rasesh Shah, C.A
For Respondent: Shri Mukesh Jain, CIT-DR
Hearing: 07/05/2026Pronounced: 27/07/2026

PER: RATNESH NANDAN SAHAY, AM:

1.

This is an appeal filed by the assessee against the order of the learned Commissioner of Income Tax (Appeals)-4, Surat [In short, ‘the ld. CIT(A)’] dated 06/02/2024 for the assessment year (AY) 2014-15, wherein the assessee has raised following grounds of appeal:

"

1.

On facts and circumstances of the case and in law, the learned CIT(A) has grossly erred in confirming addition of Rs. 7,70,456/ by estimating profit @ 10% in respect of the total credits in the bank account of the appellant less the income declared in the regular books/ITR; without appreciating that the said bank account is duly r

The order continues below.

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