ACIT,CENTRAL CIRCLE-2(3), MUMBAI, MUMBAI vs. TANISHQ BUILDERS, MUMBAI

ITA 8105/MUM/2025Status: DisposedITAT Mumbai20 February 2026AY 2024-2025Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI ARUN KHODPIA (Accountant Member)1 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that the addition was unsustainable as the evidence relied upon, primarily third-party records and statements, lacked independent corroboration and did not prove actual cash receipt by the assessee. The evidentiary threshold was not met.

What were the facts?

The Assessing Officer made an addition on account of alleged "on-money" receipts in a real estate project, based on materials seized from a third-party real estate broker. The assessee, a partnership firm, denied receiving any such on-money.

What were the issues?

Whether additions on account of alleged 'on-money' receipts can be sustained solely on the basis of third-party documents and statements without independent corroboration proving actual receipt by the assessee.

Which sections of the Income-tax Act were involved?

Section 69A,Section 132,Section 147,Section 143(3)

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, ‘E’ BENCH

Before: SHRI AMIT SHUKLA & SHRI ARUN KHODPIA

For Appellant: Shri Upvan Gupta
For Respondent: Shri Ritesh Misra, CIT DR
Hearing: 17/02/2026Pronounced: 20/02/2026

PER AMIT SHUKLA (J.M): The present cross appeals arise from the order dated 15.09.2025 passed by the Ld. Commissioner of Income-tax (Appeals)–48, Mumbai for A.Y. 2024–25, emanating from the reassessment framed under section 147 read with section 143(3) of the Income-tax Act, 1961 (“the Act”). The appeals are cross in nature, founded upon the same appellate order and the same evidentiary base, albeit assailing the same in different di

The order continues below.

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