DCIT., CENTRAL CIRCLE-3(1), HYDERABAD vs. UNITED DEVELOPER, HYDERABAD

ITA 452/HYD/2025Status: DisposedITAT Hyderabad24 September 2025AY 2016-17Bench: us as a cross-objector. Since common issues are involved in the captioned appeals and cross-objections, therefore, the same have been taken up and disposed of by a consolidated order. We shall first take up the appeal filed by the revenue and the cross-objection of the assessee firm for A.Y.2016-17, and the order therein passed shall apply mutatis mutandis for the purpose of disposing of the other appeal and cross-objection.76 pages
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What did the Tribunal hold?

The Tribunal held that the AO failed to discharge the onus of proving the unaccounted receipts. The AO did not examine purchasers or the author of the seized document and relied solely on unsubstantiated notings without corroborative evidence.

What were the facts?

During a search, incriminating documents were found suggesting unaccounted cash receipts from the sale of commercial complex shops. The Assessing Officer (AO) made additions based on these documents, alleging that the cash component of the sale consideration was not disclosed by the assessee.

What were the issues?

Whether additions made by the AO based on seized documents without corroborative evidence are sustainable. Whether the AO discharged the onus of proving undisclosed income.

Which sections of the Income-tax Act were involved?

Section 132,Section 153C

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Income Tax Appellate Tribunal, Hyderabad ‘A’ Bench, Hyderabad

For Appellant: Shri Balakrishna, CIT-DR

"ित रवीश सूद, जे.एम./PER RAVISH SOOD, J.M.

The present appeals filed by the revenue are directed against the respective orders passed by the Commi

The order continues below.

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