DY. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, MUZAFFARPUR, MUZAFFARPUR vs. RAJESH AGRAWAL, MUZAFFARPUR

ITA 400/PAT/2025Status: DisposedITAT Patna16 July 2026AY 2019-2097 pages
AI SummaryPartly Allowed

What did the Tribunal hold?

The Tribunal held that the reassessment was validly initiated based on seized materials. However, it found that some additions were made without sufficient corroborative evidence or proper verification, particularly those based on retracted statements or presumptive calculations.

What were the facts?

A search action was conducted on the assessee, a businessman dealing in Gutka and Pan Masala, leading to the discovery of incriminating documents. The Assessing Officer (AO) reopened the assessment and made several additions, including unexplained expenses, undisclosed turnover, and unexplained money.

What were the issues?

The primary issues were the validity of reassessment proceedings initiated based on search materials and the sustainability of additions made on the basis of retracted statements and presumptive calculations without corroborative evidence.

Which sections of the Income-tax Act were involved?

Section 147,Section 148,Section 69C,Section 69A

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, “PATNA” BENCH, PATNA

Before: SHRI RAJESH KUMAR, AM & SHRI PRADIP KUMAR CHOUBEY, JM

For Appellant: Shri Sh. Siddarth Agarwal, Adv
For Respondent: Md. A H Chowdhary, CIT-DR
Hearing: 20.05.2026Pronounced: 16.07.2026

Per Rajesh Kumar, AM:

These are the cross appeals preferred by the assessee and revenue against the separate orders of the ld. Commissioner of Income Tax, Appeal, Patna-3, (hereinafter referred to as the “Ld. Rajesh Agrawal; A.Ys. 2018-19 to 2023-24 CIT(A)]dated 16.05.2025 &19.05.2025, for A.Ys. 2018-19, 2019- 20, 2020-21, 2021-22, 2022-23 & 2023-24.We shall decide the appeals of

The order continues below.

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