SARAF THE JEWELLERS, CHANDIGARH,CHANDIGARH vs. THE DEPUTY/ASSISTANT COMMISSIONER OF INCOME TAX CEN-2 CHANDIGARH, CHANDIGARH

ITA 1230/CHANDI/2025Status: DisposedITAT Chandigarh10 March 2026AY 2019-20Bench: SHRI RAJPAL YADAV (Vice President), SHRI MANOJ KUMAR AGGARWAL (Accountant Member)24 pages
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What did the Tribunal hold?

The Tribunal held that the assessee had discharged the initial onus for unsecured loans by providing documentary evidence, and the AO failed to dislodge it. However, the Tribunal found no basis for the assessee's claim of mechanical approval under Section 153D, concurring with the CIT(A)'s findings.

What were the facts?

The assessee firm was subjected to search action, leading to assessment proceedings. The Assessing Officer (AO) made additions for alleged suppressed sales of properties and for unsecured loans. The assessee contested these additions, arguing that proper documentation was provided and that the approval for assessment was mechanical.

What were the issues?

Whether additions for suppressed sales and unsecured loans were justified, and whether the approval under Section 153D was validly obtained.

Which sections of the Income-tax Act were involved?

Section 68,Section 153A,Section 153D,Section 115BBE

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Cases cited in this judgment(3)Show list

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Income Tax Appellate Tribunal, “B” BENCH, CHANDIGARH

Before: HON’BLE SHRI RAJPAL YADAV & HON’BLE SHRI MANOJ KUMAR AGGARWAL, AM

Hearing: 12.02.2026Pronounced: 10.03.2026

Heard together (2 matters)

ITA No.1230/Chandi/2025
ITA No.1592/Chandi/2025

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Per Bench

1.

1 Aforesaid cross-appeals for Ass

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