PRAKSHIPTA KUMAR MOHAPATRA,JAIPUR vs. ACIT, CENTRAL CIRCLE, AJMER

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ITA 685/JPR/2025Status: DisposedITAT Jaipur19 May 2026AY 2021-222 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that making an addition for the application of income (purchase of jewellery) when the income itself was already declared would amount to double taxation. Therefore, the addition was deleted.

What were the facts?

The assessee purchased jewellery from unaccounted sources and later declared this amount in his revised income. The Assessing Officer made an addition for the purchase of jewellery, treating it as income.

What were the issues?

Whether addition on account of purchase of jewellery from unaccounted sources is permissible when the income itself has been declared by the assessee, leading to potential double taxation.

Which sections of the Income-tax Act were involved?

Section 148,Section 250

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, JAIPUR BENCHES, “SMC” BENCH, JAIPUR

Before: SHRI SANJAY GARG

Hearing: 23.03.2026Pronounced: 19.05.2026

P a g e | 1 ITA No.685/JPR/2025 Prakshipta Kumar Mohapatra IN THE INCOME TAX APPELLATE TRIBUNAL, JAIPUR BENCHES, “SMC” BENCH, JAIPUR BEFORE SHRI SANJAY GARG, JUDICIAL MEMBER ITA No.685/JPR/2025 (Assessment Year:2021-22) Prakshipta Kumar Vs. CIT(A) Mohapatra, Jaipur 5, Aayakar Bhawan, 77 IInd Floor Ganga Sagar Bhawani Singh Road, Colony B Vaishali Nagar, Jaipur Jaipur �थायीलेखासं./जीआइआरसं./PAN/GIR No:AFRPM9220Q Appellant .. Respondent

Appellant by : Sh. Vikas Soni, C.A. Respondent by : Sh. Gaurav Awasthi, JCIT

Date of Hearing 23.03.2026 Date of Pronouncement 19.05.2026 O R D E R The present appeal has been preferred by the assessee against the order of Ld. Commissioner of Income Tax (Appeals) (hereinafter referred to as “Ld. CIT(A)”) dated 04.04.2025, passed u/s 250 of the Income Tax Act, 1961 (in short “the Act”).

2.

In this appeal, the assessee has contested the addition of Rs.3,39,840/- made by the Assessing Officer (AO) on account of purchase of jewellery from unaccounted sources. Admittedly, the assessee in his

P a g e | 2 ITA No.685/JPR/2025 Prakshipta Kumar Mohapatra return of income had not offered the income on account of salary. Pursuant to the notice u/s 148 of the Act, he has declared a total income of Rs.32,88,000/-, which included the alleged unaccounted income of the assessee also. 3. Since the assessee has already declared the said income, making an addition on account of application of such income by purchasing the jewellery, would amount to double taxation of the same income. Therefore, the impugned addition is ordered to be deleted.

4.

In the result, appeal of the assessee stands allowed. Order is pronounced under provision of Rule 34 of ITAT Rules, 1963 on 19/05/2026.

Sd/- (Sanjay Garg) Judicial Member Dated 19.05.2026 Mittali, Sr. PS Copy forwarded to: 1. Appellant 2. Respondent 3. CIT 4. CIT(Appeals) 5. DR: ITAT By Order,

Asst. Registrar ITAT, Jaipur

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