DEPUTY COMMISSIONER OF INCOME -TAX, AHMEDABAD vs. PRAKASH MISRIMAL SANGHVI, AHMEDABAD

ITA 1153/AHD/2024Status: DisposedITAT Ahmedabad18 February 2025AY 2018-19Bench: SHRI T.R. SENTHIL KUMAR (Judicial Member), SHRI NARENDRA PRASAD SINHA (Accountant Member)1 pages
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What did the Tribunal hold?

The Tribunal held that the entire gross credit in miscellaneous transactions could not be taxed as income, only the undisclosed income. The Ld. CIT(A)'s approach of confirming additions to the extent of undisclosed income and deleting protective additions was found logical and rational.

What were the facts?

A search action revealed handwritten diaries with cash transaction notings, which the assessee admitted were his books of accounts for unrecorded cash transactions. The Assessing Officer (AO) made additions based on these seized materials and the assessee's statement.

What were the issues?

Whether the entire undisclosed receipts can be taxed as income, and the validity of additions made based on seized diaries and the CIT(A)'s relief.

Which sections of the Income-tax Act were involved?

Section 132,Section 148,Section 143(3),Section 147,Section 69A,Section 115BBE,Section 28

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Cases cited in this judgment(9)Show list

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Income Tax Appellate Tribunal, “C” BENCH, AHMEDABAD

Before: SHRI T.R. SENTHIL KUMAR & SHRI NARENDRA PRASAD SINHA

For Appellant: Shri S. N. Soparkar, Sr. Advocate &, Shri Parin Shah, A.R, Shri A. P. Singh, CIT-DR
For Respondent: Shri A. P. Singh, CIT-DR
Pronounced: 18/02/2025

PER BENCH: These 18 appeals are filed by the assessee & the Revenue against the combined order of the Commissioner of Income Tax

ITA Nos. 1138 to 1146, 1148 to 1155 & 11

The order continues below.

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