NAND SINGH,JAIPUR vs. ITO WARD 7(2), JAIPUR, JAIPUR

ITA 357/JPR/2025Status: DisposedITAT Jaipur23 March 2026AY 2013-145 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that the addition of Rs. 54,27,653 on account of unexplained investment in land was not justified. The assessee had fully established the source of investment in the purchase of land by producing detailed evidence before the Tribunal, including loan confirmations, lender statements, and landholding details. Therefore, this addition was deleted. Regarding the trading addition of Rs. 2,31,451, the Tribunal found that it was made on an estimated basis without pointing out any specific defect in the regularly maintained books of account. Consequently, this addition could not be sustained and was also deleted. The appeal of the assessee was allowed.

What were the facts?

The assessee, Nand Singh, filed an appeal before the Income Tax Appellate Tribunal (ITAT), Jaipur Bench, against the order of the National Faceless Appeal Centre (NFAC)/Ld. Commissioner of Income Tax Appeal (CIT(A)) dated January 23, 2025. The assessment year in question is 2013-14. The Assessing Officer (AO) had made additions of Rs. 2,31,451 as a trading addition after rejecting the assessee's books of account. Additionally, an addition of Rs. 54,27,653 was made under Section 69A for unexplained investment in agricultural land, and Rs. 11,00,000 was added for alleged failure to substantiate agricultural income. The Ld. CIT(A) partly allowed the appeal, deleting the addition of Rs. 11,00,000 but sustaining the additions for unexplained investment and estimated trading profit.

What were the issues?

1. Whether, in law and in the facts and circumstances, the Ld. CIT(A) erred in confirming the AO's action in making a trading addition of Rs. 2,31,451, and whether relief should be granted by deleting this addition. The assessee contended that the addition was made on an estimation basis without identifying specific defects in the regularly maintained books of account. The revenue supported the order of the lower authorities. 2. Whether, in law and in the facts and circumstances, the Ld. CIT(A) erred in confirming the AO's action in making an addition of Rs. 54,27,653 under Section 69A, and whether relief should be granted by deleting this addition. The assessee argued that the identity of lenders, their creditworthiness, and the genuineness of the loan transactions were fully established, supported by confirmations of loans, statements recorded under Section 131, jamabandi of lenders, agricultural receipts, bank statements, girdhavari, and income tax returns for earlier years. The revenue supported the order of the lower authorities.

Which sections of the Income-tax Act were involved?

Section 69A,Section 250,Section 143(2),Section 142(1),Section 69,Section 131

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, JAIPUR BENCHES, “B” BENCH, JAIPUR

Before: SHRI SANJAY GARG & SHRI RATNESH NANDAN SAHAY

Hearing: 19.03.2026Pronounced: 23.03.2026

Per Ratnesh Nandan Sahay, Accountant Member:

The present appeal has been preferred by assessee against the order of National Faceless Appeal Centre (NFAC)/Ld. Commissioner of Income Tax Appeal (hereinafter referred to as “Ld. CIT(A)”) dated ITA No.357/JPR/2025 Nand Singh

23.01.

2025 u/s 250 of the Income Tax Act, 1961 (hereinafter referred to as “Act”).

2.

The assessee in this appeal has taken following grounds of appeal:-

1.

In the facts and circumstances of the case and in law, Id. CIT(A) has erred in confirming the action of the ld. AO, in making addition of Rs. 2,31,451 as trading addition, The action of t

The order continues below.

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