M/S MAHADEV STONE CRUSHER,HOSHIARPUR vs. INCOME TAX OFFICER, HOSHIARPUR

ITA 555/ASR/2025Status: DisposedITAT Amritsar31 August 2026AY 2017-185 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that the transactions were recorded in the firm's books and the partners' capital contributions were sourced from their explained income as government contractors. Therefore, the addition made under Section 69A was deleted.

What were the facts?

The assessee, a newly formed partnership firm, invested Rs. 79.20 lakhs in heavy vehicles. The AO treated Rs. 15.20 lakhs, the margin money paid by the firm, as unexplained income under Section 69A. The CIT(A) confirmed this addition.

What were the issues?

Whether the margin money invested by the partnership firm in vehicles, sourced from partners' capital, is unexplained income under Section 69A, and if partners' ITRs can be considered as proof of creditworthiness.

Which sections of the Income-tax Act were involved?

Section 69A,Section 69

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, AMRITSAR BENCH, AMRITSAR.

Before: SH. S. RIFAUR RAHMAN & SH. UDAYAN DAS GUPTA

Hearing: 21.07.2026Pronounced: 31.08.2026

Per: Udayan Dasgupta, JM:

This appeal is filed by the assessee against the order of ld. CIT(A), NFAC, Delhi, passed u/s 250 of the IT Act, 1961, dated 11/07/2024, which has emanated from the order of the AO, (NFAC), passed u/s 147/ 144B of the Act, dated 23.03.2022. 2. Condonation of Delay: The appeal is belatedly filed with a delay of 277 ( two hundred seventy seven days ) , and the delay as explained by the assessee in the application for condonation has arisen due to default on the part of the earlier counsel to inform the assessee , which has led to non communication of Assessment Year: 2017-18 Page 2

the appeal order, resulting in delay. Considering the submissions made the delay is condoned and appeal is admitt

The order continues below.

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