ASSISTANT COMMISSIONER OF INCOME TAX, CHANDIGARH vs. SARAF THE JEWELLERS, PUNJAB

ITA 1594/CHANDI/2025Status: DisposedITAT Chandigarh12 March 2026AY 2021-22Bench: SHRI RAJPAL YADAV (Vice President), SHRI MANOJ KUMAR AGGARWAL (Accountant Member)1 pages
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What did the Tribunal hold?

The Tribunal held that the CIT(A) correctly deleted the addition on account of suppressed sales by comparing the assessee's business model with a franchisee, finding it not comparable. The Tribunal also concurred with the CIT(A)'s deletion of additions related to unexplained expenditure and cash found, finding the CIT(A)'s reasoning sound.

What were the facts?

The assessee, Saraf The Jeweller, was subjected to search and seizure, leading to assessment proceedings. The Assessing Officer (AO) made additions for alleged suppressed sales and unexplained expenditure. The Commissioner (Appeals) [CIT(A)] partly confirmed and partly deleted these additions.

What were the issues?

The key issues involved the validity of additions made for suppressed sales and unexplained expenditure, the applicability of Section 68 for cash credits, and the legality of the approval granted under Section 153D.

Which sections of the Income-tax Act were involved?

Section 143(3),Section 68,Section 69A,Section 115BBE,Section 153D,Section 65B

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Cases cited in this judgment(6)Show list

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Income Tax Appellate Tribunal, “B” BENCH, CHANDIGARH

Before: HON’BLE SHRI RAJPAL YADAV & HON’BLE SHRI MANOJ KUMAR AGGARWAL, AM

Hearing: 12.02.2026Pronounced: 12.03.2026

Heard together (2 matters)

ITA No.1232/Chandi/2025
ITA No.1594/Chandi/2025

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Per Bench

2

1.

1 Aforesaid cross-appeals for Assessment Year (AY) 2021-22

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