KUMAR BUILDERS,NAGPUR vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 1(1), NAGPUR, NAGPUR

ITA 572/NAG/2025Status: DisposedITAT Nagpur19 June 2026AY 2021-202210 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that the addition was made solely on the basis of loose paper notings without any corroborative evidence. The assessee's explanation that the notings were internal workings was not disproved by the AO, and no evidence of actual rental income receipt was established.

What were the facts?

The assessee, a construction firm, had its case reopened after a search action. The Assessing Officer (AO) made an addition of Rs. 42,18,500 based on loose paper notings, which he interpreted as rental income from machinery. The assessee contended that these were internal workings for machinery utilization.

What were the issues?

Whether an addition can be made solely on the basis of loose paper notings without corroborative evidence, and whether the notice issued under Section 148 was valid.

Which sections of the Income-tax Act were involved?

Section 147,Section 148,Section 151A,Section 250,Section 143(2),Section 142(1),Section 234A,Section 234B,Section 234C

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, NAGPUR BENCH :: NAGPUR

For Appellant: Shri K.P. Dewani, Advocate
For Respondent: Shri Pankaj Kumar, CIT-DR
Hearing: 11.06.2026Pronounced: 19.06.2026

PER KHETTRA MOHAN ROY, AM:

This appeal filed by the assessee is directed against the order of Commissioner of Income Tax (Appeals)-3, Nagpur (for short, “CIT(A)”), dated 15/09/2025 passed under section 250 of the Income Tax Act, 1961 (for short, “Act”) which is emanating from the assessment order dated 22.03.2025 passed u/s. 147 of the Act, for the Assessment Year (AY) 2021-22. 2. Assessee has raised the following grounds of appeal:

“1. The notice issued u/s 148 of I.T. Act 1961 is illegal, invalid and bad in law. Consequent assessment framed thereupon is liable to be cancelled.

2.

The notice u/s 148 of I.T. Act 1961 is issued by DCIT, Central Circle-2(2), Nagpur (JAO) and is not in compliance with provisions of sectio

The order continues below.

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