DEPUTY COMMISSIONER OF INCOME TAX, CENTRE-CIRCLE-6(4), MUMBAI vs. SHRI RAJIV RATAN, NEW DELHI

ITA 1434/MUM/2022Status: DisposedITAT Mumbai30 December 2022AY 2011-1222 pages
AI SummaryDismissed

What did the Tribunal hold?

The Tribunal held that the CIT(A) was justified in deleting the addition. The Indiabulls Group had already approached the Income Tax Settlement Commission and offered income related to these transactions, and the AO failed to demonstrate that the impugned amount was not included in the settlement.

What were the facts?

During a search in the Indiabulls Group, an Excel sheet was found containing records of unaccounted cash transactions, some of which were linked to 'RR P' (Shri Rajiv Rattan). The Assessing Officer (AO) added Rs. 20.63 crores as unaccounted income to the assessee's income based on these records.

What were the issues?

Whether the AO was justified in adding unaccounted cash receipts to the assessee's income when the transactions were part of a settlement application filed by a group, and whether the CIT(A) erred in relying on the settlement commission's order.

Which sections of the Income-tax Act were involved?

Section 153C,Section 245D

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, “D” BENCH, MUMBAI

Before: SHRI ABY T VARKEY & SHRI AMARJIT SINGHShri Rajiv Rattan Smt. Riddhi Mishra

For Appellant: Smt. Riddhi Mishra
Hearing: 15.11.2022Pronounced: 30.12.2022

Heard together (2 matters)

ITA No. 1434/Mum/2022
C.O. No.126/Mum/2022

Read from the judgment's own cause title. This page is filed under one of them.

Per Amarjit Singh (AM): The present appeal and cross objection filed by the revenue are directed against the order passed by the ld. CIT(A)-54, Mumbai, dated 09.12.2021 for A.Y. 2011-12. The revenue has raised the following grounds before us:

“1 On the facts and in

The order continues below.

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