VIBRANT GLOBAL CAPITAL LIMITED,MUMBAI vs. DCIT CENTRAL CIRCLE-1(2), NAGPUR

ITA 710/NAG/2025Status: DisposedITAT Nagpur31 August 2026AY 2015-165 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that the Assessing Officer must independently establish concealment of income, even if the assessment order is accepted. The addition was based solely on inferences from an excel sheet without corroborative evidence, and the assessee's explanation was not adequately rebutted.

What were the facts?

The assessee's case was subject to assessment proceedings under Section 153C following a search operation. An addition was made under Section 69A based on an excel sheet suggesting undisclosed interest income. Penalty proceedings under Section 271(1)(c) were initiated for concealment of income.

What were the issues?

Whether penalty under Section 271(1)(c) can be levied solely based on inferences from an excel sheet without independent corroboration and rebuttal of the assessee's explanation.

Which sections of the Income-tax Act were involved?

Section 153C,Section 69A,Section 271(1)(c)

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, “DB” BENCH, NAGPUR

Before: SHRI ANUBHAV SHARMA & SHRI KHETTRA MOHAN ROY

Hearing: 18.06.2026Pronounced: 31.08.2026

PER ANUBHAV SHARMA, JM:

This appeal is preferred by the assessee against the order dated 13.10.2025 of the Ld. Commissioner of Income Tax (Appeal)-3, Nagpur (hereinafter referred as Ld. First Appellate Authority or in short Ld. „The FAA‟) in DIN & Order No: ITBA/APL/S/250/2025-26/1081702932(1)

P a g e | 2 Vibrant Global Capital Limited (AYs: 2015-16) arising out of the penalty order dated 27.03.2022 u/s 271(1)(c) of the Income Tax Act, 1961 (hereinafter referred to as „the Act‟) passed by ACIT, Central Circle -1(2), Nagpur, for AY: 2015-16. 2. On hearing both

The order continues below.

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