ZAFIRUDDIN HAFIZUDDIN SYED,NAGPUR vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 1(1), NAGPUR, NAGPUR

ITA 574/NAG/2025Status: DisposedITAT Nagpur19 June 2026AY 2021-202211 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that the addition made solely on the basis of loose paper notings, without any corroborative evidence or identification of the payer, is legally unsustainable. The assessee's explanation that the notings were for internal tracking of machinery utilization was not disproved.

What were the facts?

The assessee's case was reopened under Section 147 based on a search and seizure action. The Assessing Officer (AO) made an addition of Rs. 7,69,000 as alleged rental income from machinery, based solely on loose paper notings found during the search.

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 143(2),Section 142(1),Section 250,Section 234A,Section 234B,Section 234C,Section 69

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, NAGPUR BENCH :: NAGPUR

Before: SHRI ANUBHAV SHARMA & SHRI KHETTRA MOHAN ROY

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:

Thess appeals filed by the assessee are directed against the separate orders of Commissioner of Income Tax (Appeals)-3, Nagpur, (for short, “CIT(A)”), both dated 15/09/2025 passed under section 250 of the Income Tax Act, 1961 (for short, “Act”) which are emanating from the separate assessment orders both dated 22.03.2025 passed u/s. 147 of the Act, for the Assessment Years (AYs) 2020- 21 & 2021-22 respectively.

ITA Nos. 573 & 574/NAG/2025 (Zafiruddin Hafizuddin Syed)

2.

Since the facts and issues involved in both the appeals are identical, they were heard together and are being disposed of by this consolidated order. For the sake of

The order continues below.

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