SAHANU SPONGE AND POWER PRIVATE LIMTED,PANAJI , GOA vs. INCOME TAX OFFICER , CIRCLE 1(1), PANAJI-GOA

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ITA 123/PAN/2026Status: DisposedITAT Panaji05 August 2026AY 2014-1531 pages
AI SummaryPartly Allowed

What did the Tribunal hold?

The Tribunal held that Section 69C is not applicable to unaccounted purchases not appearing in the books. Following the rule of consistency and a prior year's assessment, it was decided that only the profit element on unaccounted sales should be taxed.

What were the facts?

The assessee's assessment was reopened based on information about unaccounted purchases and sales. The Assessing Officer made an addition for unexplained expenditure under Section 69C based on alleged unaccounted purchases, which the assessee contested.

What were the issues?

Whether Section 69C is applicable to unaccounted purchases, and whether the addition should be based on profit element of unaccounted sales following the rule of consistency.

Which sections of the Income-tax Act were involved?

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

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, PANAJI BENCH, ‘DB’ PANAJI

Before: DR.MANISH BORAD & SHRI VINAY BHAMORE

For Appellant: Shri P.K. Bansal (virtual)
For Respondent: Smt. Rijula Uniyal (virtual)
Hearing: 11.06.2026Pronounced: 05.08.2026

आदेश की प्रतिलिपि अग्रेपिि / Copy of the Order forwarded to : अपील र्थी / The Appellant. 1. प्रत्यर्थी / The Respondent. 2. 3. The Pr. CIT concerned. विभ गीय प्रतितनधि, आयकर अपीलीय अधिकरण, Panaji 4. ‘DB’ Bench / DR, ITAT, Panaji ‘DB’ Bench ग र्ड फ़ इल / Guard File. 5.

आिेश नुस र / BY ORDER,

// True Copy // Assistant Registrar, आयकर अपीलीय अधिकरण, Panaji/ ITAT, Panaji

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