DCIT,CENTRAL CIRCLE-1,RANCHI, RANCHI vs. JAIKASHI TRANDING & FINANCE CO. PRIVATE LIMITED, RANCHI

ITA 435/RAN/2024Status: DisposedITAT Ranchi20 April 2026AY 2020-215 pages
AI SummaryDismissed

What did the Tribunal hold?

The Tribunal upheld the CIT(A)'s decision to delete the addition of Rs. 4 crores, stating that additions must be based on evidence and not solely on disclosures made during survey proceedings. The Tribunal also affirmed the CIT(A)'s estimation of income at 2% on the stock shortage.

What were the facts?

During a survey, discrepancies in stock and other financial transactions were found, leading the assessee to disclose an additional income of Rs. 4 crores. However, the assessee did not offer this amount for taxation in their return. The Assessing Officer made an addition of Rs. 4 crores based on this disclosure.

What were the issues?

Whether an addition can be made solely on the basis of a disclosure made during a survey without corroborative evidence. Whether a stock discrepancy found during a survey can lead to an addition based on the entire discrepancy or only a portion.

Which sections of the Income-tax Act were involved?

Section 68

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, RANCHI BENCH, RANCHI

Before: SHRI GEORGE MATHAN & SHRI RATNESH NANDAN SAHAY

For Appellant: Shri Devesh Poddar, AR
For Respondent: Shri Ashish Kumar Deharia, CIT-DR, Shri Devesh Poddar, AR
Hearing: 20/04/2026Pronounced: 20/04/2026

PER: BENCH

1.

This is an appeal filed by the revenue against the order of the ld. CIT(A), Patna-3, Patna in Appeal No. CIT(A), Patna-3/10460/2019-20 dated 25/09/2024 for the A.Y. 2020-21. The revenue in its appeal has raised following grounds of appeal:

"

1.

That on the facts and in the circumstances of the case and in law, the Ld. CIT(A) erred in deleting the addition of Rs.3,96,81,187/- holding that there was no specific adverse findings drawn by the AD to support the disclosure made by the assessee and the AO has made these additions solely on the basis of the statement recorded during the survey proceedings which is not acceptable.

The order continues below.

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