RAJESH KUMAR TIWARI, RAIPUR,RAIPUR vs. INCOME TAX OFFICER, WARD-2(2), RAIPUR, RAIPUR

ITA 844/RPR/2025Status: DisposedITAT Raipur20 March 2026AY 2012-13Bench: SHRI PARTHA SARATHI CHAUDHURY (Judicial Member), SHRI AVDHESH KUMAR MISHRA (Accountant Member)1 pages
AI SummaryRemanded

What did the Tribunal hold?

The Tribunal held that the net profit rate applied by the AO was not based on comparable cases or past trends. The reasoning of the CIT(A) for not admitting additional evidence was also found unsatisfactory. Consequently, the Tribunal set aside the impugned order and remanded the matter back to the CIT(A).

What were the facts?

The assessee, proprietor of M/s Shree Dhanlaxmi Traders, filed an original return of income. The case was reopened under Section 148 of the Act. The Assessing Officer (AO) completed the assessment ex-parte, noting the assessee's business turnover was not disclosed and applying a net profit of 21.67%, adding Rs. 8,99,852/-. Additionally, Rs. 74,76,720/- was added as unexplained money under Section 69A of the Act.

What were the issues?

The primary issues were the applicability of the net profit rate of 21.67% and the taxability of Rs. 74,76,720/- as unexplained money under Section 69A of the Income Tax Act, 1961.

Which sections of the Income-tax Act were involved?

Section 147,Section 148,Section 131,Section 69A,Section 250

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, RAIPUR BENCH, RAIPUR

Before: SHRI PARTHA SARATHI CHAUDHURY, JM & SHRI AVDHESH KUMAR MISHRA, AM

Hearing: 17/03/2026

Per Avdhesh Kumar Mishra, AM:

This appeal for Assessment Year (‘AY’) 2012-13 filed by the assessee is directed against the order dated 31.10.2025 of the Commissioner of Income Tax (Appeals), National Faceless Appeal Centre (‘NFAC’), Delhi [‘CIT(A)’] passed under section 250 of the Income Tax Act, 1961 (‘Act’).

2.

The assessee has challenged the impugned o

The order continues below.

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