SHRI AMBICA GARMENTS,JODHPUR vs. ACIT, CENTAL CIRCLE-3, JAIPUR

ITA 56/JPR/2025Status: DisposedITAT Jaipur15 October 2025AY 2014-15150 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that when the AO rejects books of account and estimates profit, no separate addition under Section 68 can be made for unexplained credits, as the estimation encompasses such discrepancies. Furthermore, opening balances carried forward from prior years, which do not represent fresh credits in the current year, cannot be subject to addition under Section 68.

What were the facts?

The appeals concern assessment years 2014-15 to 2019-20 for two assessees, M/s. Shri Ambica Garments and Shri Sanjay Kumar Karnani. The core issue revolves around additions made by the Assessing Officer (AO) and confirmed by the CIT(A) on account of alleged unexplained capital, loans, and estimated gross profit.

What were the issues?

Whether additions under Section 68 are permissible when the AO has already rejected books of account and estimated profit under Section 145(3)? Can opening balances carried forward from previous years be treated as unexplained credits under Section 68?

Which sections of the Income-tax Act were involved?

Section 68,Section 145(3),Section 153A,Section 250

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Cases cited in this judgment(24)Show list

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Income Tax Appellate Tribunal, JAIPUR BENCHES,”B” JAIPUR

Before: DR. S. SEETHALAKSHMI, JM & SHRI RATHOD KAMLESH JAYANTBHAI,

For Appellant: Shri Deepak Sharma, Adv
Hearing: 17/09/2025Pronounced: 15/10/2025

PER: RATHOD KAMLESH JAYANTBHAI, AM The present bunch of

The order continues below.

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