SUBHASH PARETA,KOTA RAJASTHAN vs. ACIT, CIRCLE-2, KOTA, KOTA RAJASHTAN

ITA 114/JPR/2025Status: DisposedITAT Jaipur19 May 2025AY 2011-12Bench: SHRI GAGAN GOYAL (Accountant Member), SHRI NARINDER KUMAR (Judicial Member)1 pages
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What did the Tribunal hold?

The Tribunal found that the authorities below made additions based on conjectures and surmises without proper evidence. The grounds raised by the assessee were allowed, and the orders of the authorities below were set aside with a direction to delete the addition.

What were the facts?

The assessee's income was assessed at a significantly higher amount than returned, following a survey and special audit. The CIT(A) confirmed most additions, but the ITAT set aside one issue for further verification. In the second round, the CIT(A) sustained the addition, leading to the present appeal.

What were the issues?

The primary issue was the sustainability of an addition made under Section 69C for unexplained expenditure, particularly concerning payments documented in Annexure A-24, and whether the CIT(A) properly addressed the assessee's contentions on its reliability.

Which sections of the Income-tax Act were involved?

Section 69C,Section 145(3),Section 292C

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Income Tax Appellate Tribunal, JAIPUR BENCH “A”, JAIPUR

Before: SHRI GAGAN GOYAL & SHRI NARINDER KUMAR

Hearing: 14/05/2025Pronounced: 19/05/2025

PER GAGAN GOYAL, A.M:

These two appeals by the assessee are directed against the order of CIT(A), Jaipur -04 dated 19.12.2024 and Addl. CIT/JCIT(A)-01 Coimbatore dated 06.02.2025 passed u/s. 250 r.w.s 254and 250 of the Income Tax Act, 1961 respectively (in short ‘the Act’).

In ITA No. 114/JPR/2025 for A.Y. 2011-12, the assessee has raised the following grounds of appeal:

1.

That the Ld. AO grossly erred in making addition by invoking sec. 69C of Rs. 1, 18,34,723/- and in first round the Ld. CIT(A) allowed the ground, then the department filed appeal before t

The order continues below.

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