ACIT(EXEMPTION), CIRCLE-2, AHMEDABAD, AHMEDABAD vs. SHREE SURTI MODH VANIK SARVAJANIK TRUST , SURAT

ITA 1668/AHD/2025Status: DisposedITAT Ahmedabad10 September 2026AY 2018-199 pages
AI SummaryDismissed

What were the facts?

The Assessing Officer made an addition of Rs. 13,69,41,394/- under Section 68, treating a difference between FDR/bank balances and accumulated income as unexplained. The assessee, a charitable trust, provided details of investments and accumulations over several years.

What did the Tribunal hold?

The Tribunal upheld the deletion of the addition by the CIT(A), finding that the Assessing Officer's comparison was erroneous. The Tribunal noted that the FDR balances represented funds accumulated over many years, not just the period under consideration, and the assessee had provided sufficient evidence.

What were the issues?

Whether the difference between total investment in FDRs/bank balances and specific period's accumulation constitutes unexplained income under Section 68. Whether the CIT(A) was justified in deleting the addition made by the AO.

Which sections of the Income-tax Act were involved?

Section 68,Section 11(1),Section 11(2),Section 115BBE

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, “B” BENCH, AHMEDABAD

Before: DR. BRR KUMAR & SHRI RAHUL CHAUDHARY

For Appellant: Shri Ram Tiwari, CIT-DR
For Respondent: Shri P M Jagasheth, AR
Hearing: 23.07.2026Pronounced: 10.09.2026

PER DR. BRR KUMAR, VICE PRESIDENT:

The present appeal has been filed by the Revenue against the order of the Ld. Commissioner of Income Tax (Appeals), National Faceless Appeal Centre (hereinafter referred to as “NFAC”), Delhi (hereinafter referred to as “CIT(A)”), dated 25.06.2025 passed under Section 250 of the Income Tax Act, 1961 (hereinafter referred to as the “Act”) and relates to Assessment Year (A.Y.) 2018-19. 2. The ground of appeals raised by the Revenue is as under:

“1. Whether on the facts and in circumstances of the case, Ld. CIT(A), NFAC is justified in deleting the addition of Rs. 13,69,41,394/- treated as alleged unexplained income u/s. 68 of the

The order continues below.

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