SKZ DEVELOPERS LLP,AHMEDABAD vs. THE DCIT, CENT. CIRCLE-1(4), AHMEDABAD

ITA 1678/AHD/2024Status: DisposedITAT Ahmedabad09 January 2026AY 2022-23Bench: Shri Sanjay Garg, Judicial Member And Annapurna Gupta (Accountant Member)19 pages
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What did the Tribunal hold?

The Tribunal held that the CIT(A)'s action of estimating on-money receipts and profits was not justified. It also upheld the CIT(A)'s decision to estimate deemed rent at 3% of the project cost.

What were the facts?

The assessee, SKZ Developers LLP, was subjected to search and seizure operations which revealed undisclosed cash transactions related to the sale of real estate units. The Assessing Officer (AO) alleged that the assessee received 'on-money' on the sale of units in two projects, estimating the total on-money receipt at over Rs. 53 crore.

What were the issues?

Whether the AO and CIT(A) were justified in estimating 'on-money' receipts based on seized material and whether deemed rent addition was appropriate.

Which sections of the Income-tax Act were involved?

Section 132,Section 23(5)

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Income Tax Appellate Tribunal, “ A” BENCH, AHMEDABAD

Before: Shri Sanjay Garg & Annapurna Gupta

Consolidated Appeals (3)

ITA 1678/Ahd/2024AY 2022-23
ITA 1728/Ahd/2024AY 2021-22
ITA 1729/Ahd/2024AY 2022-23
For Appellant: Shri Vartik Chokshi, AR
For Respondent: Shri Alpesh Parmar, CIT-DR
Hearing: 16/10/2025Pronounced: 09/01/2026

Per Sanjay Garg, Judicial Member:

The captioned are the cross-appeals by the Assessee and the Revenue for Assessment Year (AY) 2021-22 and for AY 2022-23 respectively against the common order dated 29.07.2024 of the Ld. Commissioner of Income Tax

ITA Nos.1677 & 1688/Ahd/2024 (By Assessee) & ITA Nos.

The order continues below.

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