MUKESH JAIN,INDORE vs. THE ACIT (CENTRAL)-2, INDORE, INDORE

ITA 928/IND/2024Status: DisposedITAT Indore21 January 2026AY 2014-15Bench: SHRI SIDDHARTHA NAUTIYAL (Judicial Member), SHRI BHAGIRATH MAL BIYANI (Accountant Member)1 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that the seized documents did not contain the assessee's complete name, address, PAN, or signature, nor were they found in his possession. Furthermore, the assessee was not confronted with the statement of Shri Dilip Kumar Jain, a violation of natural justice. The Tribunal also noted the lack of evidence for a tripartite arrangement in the alleged hundi transactions.

What were the facts?

A search and seizure action was conducted at MRJ Group premises, where loose papers and hundies were seized. Based on these documents, the Assessing Officer initiated proceedings under Section 153C against the assessee, Mukesh Jain, for Assessment Years 2014-15 and 2015-16. Additions were made for alleged unexplained cash loans.

What were the issues?

Whether additions made under Section 69 based on seized documents from a third party, without proper corroboration and without confronting the assessee with related statements, are sustainable?

Which sections of the Income-tax Act were involved?

Section 153C,Section 69,Section 115BBE,Section 271(1)(c),Section 132

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, INDORE BENCH, INDORE

Before: SHRI SIDDHARTHA NAUTIYAL & SHRI BHAGIRATH MAL BIYANI

For Appellant: CA Sh. S.N. Agrawal
Hearing: 18/12/2025Pronounced: 21/01/2026

Heard together (2 matters)

I.T.A. No.927/Ind/2024
I.T.A. No.928/Ind/2024

Read from the judgment's own cause title. This page is filed under one of them.

PER SIDDHARTHA NAUTIYAL - JM: Both these appeals have been filed by the assessee against the common order of the Commissioner of Income Tax (Appeals)-3, Bhopal, [hereinafter referred to as the “the CIT(A)] dated 23/10/2024 passed for Assessment Years (AYs) 2014-15 & 2015-16. Since common facts and issues for consideration are involved for both the years under consideration before us, these appeals are being taken up together (grounds extracted from AY 2014- 15).

ITA No.928/Ind/2024 for AY 2014-15

ITA Nos.927 & 928/Ind/2024 Mukesh Jain vs. ACIT (Central)-

The order continues below.

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