THE INCOME TAX OFFICER-WARD-2,, JUNAGADH vs. SHRI DAMJIBHAI LEKHRAJBHAI THAVRANI,, JUNAGADH

ITA 31/RJT/2019Status: DisposedITAT Rajkot19 June 2025AY 2009-1053 pages
AI SummaryRemanded

What did the Tribunal hold?

The tribunal considered the nature of the assessee's business, specifically whether they operated as an 'Angadiya' or 'Shroff', or were involved in money laundering. The ITAT examined the legal distinction between these activities and their implications for unexplained credits.

What were the facts?

The Income Tax Appellate Tribunal (ITAT) heard a consolidated set of appeals concerning unexplained cash deposits in bank accounts. The Assessing Officer (AO) made additions based on these deposits, which the Commissioner of Income Tax (Appeals) partially deleted.

What were the issues?

The primary issues were whether the cash deposits constituted unexplained income and if the assessee's business activities qualified as legitimate 'Angadiya' or 'Shroff' operations, or if they were engaged in illicit money laundering.

Which sections of the Income-tax Act were involved?

Section 153A,Section 144,Section 147,Section 143(3),Section 271(1)(c)

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Cases cited in this judgment(6)Show list

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IN THE INCOME TAX APPELLATE TRIBUNAL, RAJKOT BENCH, RAJKOT BEFORE DR. ARJUN LAL SAINI, ACCOUNTANT MEMBER & DINESH MOHAN SINHA, JUDICIAL MEMBER आयकर अपील सं./ITA No. 134 & 135/RJT/2023 (निर्धारणवर्ष / Assessment Years: (2007-08 & 2008-09)

Income Tax Officer, Ward- Shri Kherajmal Lekhrajbjai 1(2)(1), Aaykar Bhavan, 5th Vs. Thavrani, 4- Parsana Nagar, Shri Floor, Room No. 517, Race Vaheguru Grupa, Near Refugee Course Ring Road, Rajkot-360 Colony, Rajkot-360 001 001 स्थायी लेखा सं./जी आइ आर सं./PAN/GIR No.: ADRPT 5807 E (Appellant) (Respondent) CO. No. 01&02/RJT/2023 (a/o ITA No.134 & 135/Rjt/2023) (निर्धारण वर्ष/Assessment Year: (2007-08 & 2008-09)

Shri Kherajmal Lekhrajbjai The Income Tax Officer, Ward- Thavrani, 4- Parsana Nagar, Shri 1(2)(1), Aaykar Bhavan, 5th Floor, Colony, Rajkot-360 001 Road, Rajkot-360001 स्थायी लेखा सं./जी आइ आर सं./PAN/GIR No.: ADRPT 5807 E (Applicant) (Respondent) आयकर अपील सं./ITA No. 16/RJT/2019 (निर्धारणवर्ष / Assessment Year: (2010-11)

Damjibhai Lekharj Tharvani Income Tax Officer, Ward- C/o. Sarda & Sarda, CAs, 1st Floor, 1(2)(4), Aaykar Bhavan, 5th "Sakar" Opp. Rajkumar College, Dr. Vs. F

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