SHRIYA PROPERTIES,HUBLI vs. ACIT, CENTRAL CIRCLE, HUBLI-DHARWAD

ITA 2086/BANG/2024Status: DisposedITAT Bangalore25 May 2026AY 2019-2036 pages
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What were the facts?

The assessee, a real estate firm, was subjected to search and seizure proceedings. The Assessing Officer made several additions to the income, including disallowance of partner's remuneration, estimated disallowance of sundry creditors, negative cash balance, disallowance of depreciation, and alleged on-money receipts. The assessee appealed these additions.

What did the Tribunal hold?

The Tribunal held that for AY 2015-16, no incriminating material was found during the search relevant to the assessment year, and thus the additions made under section 153A were deleted. For other assessment years, certain additions were deleted based on similar findings for AY 2019-20, while others were remitted back to the Assessing Officer for fresh adjudication.

What were the issues?

Whether additions made under Section 153A are sustainable in the absence of incriminating material for the relevant assessment year, and the validity of various additions made by the Assessing Officer.

Which sections of the Income-tax Act were involved?

Section 153A,Section 40(b),Section 69C,Section 115BBE,Section 40(a)(ia),Section 43B,Section 36

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, “B’’BENCH: BANGALORE

Before: SHRI PRASHANT MAHARISHI & SHRI KESHAV DUBEY

Hearing: 24.03.2026Pronounced: 25.05.2026

PER KESHAV DUBEY, JUDICIAL MEMBER:

These cross appeals by the revenue and assessee are directed against the order of the ld. CIT(A)-2, Panaji, Goa dated 22/07/2024 vide DIN: ITBA/APL/M/250/2024-25/1066891788(1) for the AY 2015-16 and against the common order of the ld. CIT(A)-2, Panaji,

ITA Nos.2033, 2034, 2084, 2085 & 2086/Bang/2024 Shriya Properties,

The order continues below.

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