SIX TWENTY REALTY PVT. LTD.,RAJKOT vs. DCIT, CC-1, RAJKOT, RAJKOT

ITA 785/RJT/2024Status: DisposedITAT Rajkot11 March 2026AY 2018-19Bench: DR. ARJUN LAL SAINI (Accountant Member), DR. DINESH MOHAN SINHA (Judicial Member)20 pages
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What did the Tribunal hold?

The Tribunal held that unaccounted profit from 'on-money' receipts should be taxed in the year the sale deed is executed, not when the 'on-money' was received. It also noted that ICDS-III was not applicable to the assessee.

What were the facts?

During a survey, the assessee, a real estate developer, was found to have unaccounted cash receipts and payments, primarily from 'on-money' received on sale of flats. The Assessing Officer reopened the case and made additions based on this.

What were the issues?

The primary issues were the validity of proceedings initiated under Section 147/148 and the year in which 'on-money' receipts should be taxed for a real estate developer.

Which sections of the Income-tax Act were involved?

Section 133A,Section 143(3),Section 147,Section 148,Section 148A,Section 151,Section 145

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Income Tax Appellate Tribunal, RAJKOT BENCH, RAJKOT

Before: DR. ARJUN LAL SAINI & DR. DINESH MOHAN SINHA

Hearing: 16/01/2026Pronounced: 11/03/2026

Per, Bench: Captioned appeals filed by the Assessee and Revenue, pertaining to Asse

The order continues below.

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