DCIT, CENTRAL CIRCLE-1(4), BENGALURU vs. SRI DEVARAJ URS EDUCATIONAL TRUST FOR BACKWARD CLASSES, KOLAR

ITA 1547/BANG/2024Status: DisposedITAT Bangalore08 September 2025AY 2017-1853 pages
AI SummaryDismissed

What did the Tribunal hold?

The Tribunal held that the seized materials, including the Excel sheet and agent's documents, along with statements, constituted incriminating evidence of capitation fee collection. The AO's addition was based on these corroborated materials and not mere estimation.

What were the facts?

During a search, an Excel sheet was found detailing capitation fees collected from doctors for PG courses. This was corroborated by documents and statements from an agent involved in admissions. The Assessing Officer (AO) added Rs. 23,77,50,000/- on account of alleged capitation fees.

What were the issues?

Whether the seized documents and statements constitute incriminating material to justify the addition of capitation fees, and if the AO correctly applied presumptions and corroborative evidence.

Which sections of the Income-tax Act were involved?

Section 132,Section 132(4),Section 131(1),Section 292C,Section 133(6)

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Cases cited in this judgment(1)Show list

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Income Tax Appellate Tribunal, A BENCH, BANGALORE

Before: SHRI WASEEM AHMED & SHRI KESHAV DUBEY

For Appellant: Shri Sandeep, C.A
For Respondent: Shri Murali Mohan, CIT (DR)
Hearing: 16.07.2025Pronounced: 08.09.2025

ITA No.1060-1559-1560-1561/Bang/2024 & 903-1547-1548-1549/Bang/2024 PER WASEEM AHMED, ACCOUNTANT MEMBER:

This is a set of 8 cross appeals filed by the assessee and the revenue arising from the order of Commissioner of Income Tax (Appeal) [hereafter learned CIT(A)] for A.Ys.2017-18 to 2019-2

The order continues below.

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