MOHANLAL TARACHAND CHELARAMANI,GODHRA vs. ITO, WARD 1, GODHRA, GODHRA

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ITA 1883/AHD/2025Status: DisposedITAT Ahmedabad24 April 2026AY 2020-218 pages
AI SummaryPartly Allowed

What did the Tribunal hold?

The Tribunal held that while the addition was based on seized documents, taxing the entire purchase amount was incorrect. It directed the Assessing Officer to restrict the addition to the profit element embedded in the alleged purchases.

What were the facts?

The assessee, a firecracker trader, faced an addition of Rs. 22,50,000/- for unaccounted purchases based on seized documents from a search on another entity. The Assessing Officer rejected the assessee's explanation and denied cross-examination.

What were the issues?

Whether the entire amount of alleged unaccounted purchases can be added to income, or only the profit element embedded therein, and whether denial of cross-examination vitiates the addition when based on documentary evidence.

Which sections of the Income-tax Act were involved?

Section 69C,Section 132,Section 147,Section 148,Section 132(4)

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, “SMC” BENCH, AHMEDABAD

Before: SMT. ANNAPURNA GUPTA & SHRI SIDDHARTHA NAUTIYAL

For Appellant: Shri Chetan Agarwal, AR
For Respondent: Shri Girish Parihar, Sr. DR
Hearing: 23.03.2026

आदेश की �ितिलिप अ�ेिषत/Copy of the Order forwarded to : 1. अपीलाथ� / The Appellant 2. ��थ� / The Respondent. 3. संबंिधत आयकर आयु� / Concerned CIT 4. आयकर आयु�(अपील) / The CIT(A)- 5. िवभागीय �ितिनिध, आयकर अपीलीय अिधकरण, अहमदाबाद / DR, ITAT, Ahmedabad 6. गाड� फाईल / Guard file. आदेशानुसार/ BY ORDER,

उप/सहायक पंजीकार (Dy./Asstt.Registrar) आयकर अपीलीय अिधकरण, अहमदाबाद / ITAT, Ahmedabad

1.

Date of dictation 20.04.2026 (Dictated over dragon software) 2. Date on which the typed draft is placed before the Dictating Member 21.04.2026 3. Other Member………………… 4. Date on which the approved draft comes to the Sr.P.S./P.S .04.2026 5. Date on which the fair order is placed before the Dictating Member for pronouncement 24.04.2026 6. Date on which the fair order comes back to the Sr.P.S./P.S 24.04.2026 7. Date on which the file goes to the Bench Clerk 24.04.2026 8. Date on which the file goes to the Head Clerk…………………………………... 9. The date on which the file goes to the Assistant Registrar for signature on the order…………………….. 10. Date of Dispatch of the Order……………………………………

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