SHRI KAMLESH DEORAJ JAIN,GANDHIDHAM KUTCHH vs. THE ITO WARD 1 , GANDHIDHAM

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ITA 62/RJT/2025Status: DisposedITAT Rajkot21 May 2025AY 2018-19Bench: DR. ARJUN LAL SAINI (Accountant Member), SHRI DINESH MOHAN SINHA (Judicial Member)1 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that the transactions were circular in nature and therefore, Section 68 was inapplicable. The addition was limited to the difference between sales and purchases, along with a small commission income.

What were the facts?

The assessee's case was reopened due to unexplained purchases of salt amounting to Rs. 43,75,64,479/-. The Assessing Officer observed circular transactions between various entities, including the assessee's proprietorship, M/s. Smita Enterprises.

What were the issues?

Whether purchases made through circular transactions can be treated as unexplained cash credit under Section 68, and whether the Assessing Officer erred in rejecting books of accounts without proper justification.

Which sections of the Income-tax Act were involved?

Section 68,Section 147,Section 145(3)

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Before: DR. ARJUN LAL SAINI & SHRI DINESH MOHAN SINHA

Hearing: 29/04/2025Pronounced: 21/05/2025

आदेश क� �ितिलिप अ�ेिषत/ Copy of the order forwarded to :  अपीलाथ�/ The Appellant  ��यथ�/ The Respondent  आयकर आयु�/ CIT  आयकर आयु�(अपील)/ The CIT(A)  िवभागीय �ितिनिध, आयकर अपीलीय आिधकरण, राजकोट/ DR, ITAT, RAJKOT  गाड�फाईल/ Guard File

By order/आदेश से,

सहायक पंजीकार आयकर अपील�य अ�धकरण, राजकोट

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