PARTHIV JAWAHARBHAI SHAH,AHMEDABAD vs. THE ITO, WARD-1(3)(1), AHMEDABAD

ITA 1030/AHD/2024Status: DisposedITAT Ahmedabad18 February 2026AY 2013-14Bench: SHRI SANJAY GARG (Judicial Member), SMT. ANNAPURNA GUPTA (Accountant Member)21 pages
AI SummaryPartly Allowed

What did the Tribunal hold?

The Tribunal held that the assessee was a conduit for fund circulation and not the beneficiary, thus the entire amount could not be taxed as unexplained credit. However, the quantum of transactions needed verification to correctly compute the commission income.

What were the facts?

The assessee received a large sum of money from an entity suspected of being a dummy for fund circulation. The Assessing Officer treated these receipts as unexplained cash credits. The CIT(A) held the assessee to be a conduit and directed addition of commission income at 2% on the transaction amount.

What were the issues?

Whether the entire receipts from the suspect entity should be treated as unexplained cash credit, and if not, whether the assessee is liable for commission income as a conduit.

Which sections of the Income-tax Act were involved?

Section 68,Section 148

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, “C” BENCH, AHMEDABAD

Before: SHRI SANJAY GARG & SMT. ANNAPURNA GUPTA

For Appellant: Shri S. N. Soparkar, Sr. Advocate &, Ms. Urvashi Sodhan, A.R
For Respondent: Shri Rignesh Das, CIT. DR
Hearing: 17/12/2025Pronounced: 18/02/2026

PER ANNAPURNA GUPTA, AM: The cross appeals filed by the Assessee and Revenue are against the order passed by the Ld. Commissioner of Income Tax (Appeals), National Faceless Appeal Centre (hereinafter referred to as “NFAC”), Delhi (hereinafter referred to as ITA Nos.1030 & 1038/Ahd/2024 [Parthiv Jawaharbhai Shah] A.Y. 2013-14 - 2 – “CIT(A)”) dated 19.03.2024 , under Section 25

The order continues below.

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