SHREYANSH ANILKUMAR SHAH,NA vs. ARIVS.INCOME TAX OFFICER, WARD - 5, NAVSARI

ITA 727/SRT/2023Status: DisposedITAT Surat26 September 2025AY 2010-11Bench: SHRI DINESH MOHAN SINHA (Judicial Member), SHRI BIJAYANANDA PRUSETH (Accountant Member)1 pages
AI SummaryPartly Allowed

What did the Tribunal hold?

The Tribunal held that while the reopening of assessment was justified as the assessee failed to disclose details of bank accounts and cash/credit entries, the addition of the entire amount was excessive. Citing precedents, the Tribunal stated that only a reasonable profit element should be taxed for unaccounted business transactions or collection activities.

What were the facts?

The assessee filed his return for AY 2010-11 declaring income of Rs.1,51,020/-. Subsequently, the case was reopened under section 147, alleging undisclosed cash deposits of Rs.21,20,783/- in ICICI bank accounts, Rs.3,01,995/- in HDFC and Andhra Bank accounts, and other credit entries of Rs.8,30,859/-. The Assessing Officer (AO) added these amounts to the total income as unexplained cash credits.

What were the issues?

Whether the reopening of assessment under Section 147 was valid, and whether the entire cash deposits and credit entries amounting to Rs.32,53,637/- could be treated as unexplained income under Section 68 of the Act.

Which sections of the Income-tax Act were involved?

Section 143(3),Section 147,Section 148,Section 68,Section 133(6),Section 142(1),Section 143(2),Section 250

AI-generated summary — verify with the full judgment below

Cases cited in this judgment(2)Show list

Detected automatically from the text. Citations are also linked where they appear in the judgment. The count shows how many other judgments on BharatTax rely on the same authority.

Before: SHRI DINESH MOHAN SINHA & SHRI BIJAYANANDA PRUSETH

Hearing: 22/07/2025Pronounced: 26/09/2025

PER BIJAYANANDA PRUSETH, AM: This appeal by the assessee emanates from the order passed under section 250 of the Income-tax Act, 1961 (in short, 'the Act’) dated 26.07.2023 by the National Faceless Appeal Centre (NFAC), Delhi/Commissioner of Income-tax Appeal [in short, the ‘CIT(A)’] for the assessment year (AY) 2010-11, which in turn arises out of assessment order passed by the Assessing Officer (in short, ‘AO’) u/s 143(3) r.w.s. 147 of the Act on 27.10.2017.

The order continues below.

Read the full judgment

A free account opens 10 full judgments a month. Re-reading one you have already opened does not count again.

Create a free accountSign in

See plans and prices

The summary, the parties, the sections and the citations above are open to everyone and always will be. Only the text of the order and the PDF are metered.

More judgments on Section 147

All 49,210 judgments and leading authorities on Section 147 →

Recent GST High Court judgments

Search GST case law →