SHRI JITESH JAYANTIBHAI JASANI,RAJKOT vs. THE ITO WARD-3 (1) (1), RAJKOT, RAJKOT

ITA 869/RJT/2025Status: DisposedITAT Rajkot25 September 2026AY 2019-206 pages
AI SummaryPartly Allowed

What did the Tribunal hold?

The Tribunal found that the assessee had not filed complete documents before the AO and some submissions were self-serving. Therefore, while some relief was warranted, complete relief could not be granted. The Tribunal directed the AO to make an addition of Rs. 37,000/- at a normal rate of income tax, not under Section 115BBE.

What were the facts?

The assessee purchased a property and the Assessing Officer (AO) made an addition of Rs. 3,70,000/- on account of alleged on-money payment. The Commissioner of Income Tax (Appeals) upheld this addition. The assessee appealed to the Tribunal, arguing that they had submitted bank statements and registered documents to prove the genuineness of the transaction.

What were the issues?

Whether the addition of Rs. 3,70,000/- on account of alleged on-money payment is justified, and if so, whether it should be taxed under Section 115BBE.

Which sections of the Income-tax Act were involved?

Section 69A,Section 115BBE,Section 147,Section 143(3),Section 250

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, “SMC”

Before: Dr. Arjun Lal Saini

For Appellant: Shri Fenil H. Mehta. Ld. AR
For Respondent: Shri Shishir Kumar, Ld. SR DR
Hearing: 30/07/2026

Per, Dr. Arjun Lal Saini, AM: Captioned appeal filed by the assessee, pertaining to assessment year (AY) 2019-20, is directed against the order passed under section 250 of the Income-tax Act, 1961 (hereinafter referred to as ‘the Act’) dated 30.09.2025 by the National Faceless Appeal Centre (NFAC), Delhi/Commissioner of Income Tax (Appeals) [in short ‘Ld.CIT(A)’] which in turn arises out of an assessment order passed by the Assessing Officer (in short ‘AO’) u/s 147 r.w.s. 143(3) of the A

The order continues below.

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