SH. GOPAL SINGH SUNDA,SIKAR vs. DCIT, CENTRAL CIRCLE-2, JAIPUR, JAIPUR
What did the Tribunal hold?
The Tribunal held that the opening balance of loans claimed by the assessee remained unverified, unaccounted, and untaxed. The Tribunal also noted discrepancies in the assessee's working and the lack of identity and whereabouts of the parties involved in the transactions.
What were the facts?
During a search operation, a diary detailing cash loan transactions of the assessee was seized. The Assessing Officer (AO) treated certain loan advances and interest income as undisclosed income, disallowing the claim of an opening balance. The Commissioner of Income Tax (Appeals) confirmed the AO's additions.
What were the issues?
Whether the opening balance of loans claimed by the assessee, derived from a seized diary, can be accepted as a source for subsequent transactions without proper verification. Whether the additions made on account of unexplained advances and alleged interest income are justified.
Which sections of the Income-tax Act were involved?
AI-generated summary — verify with the full judgment below
Income Tax Appellate Tribunal, JAIPUR BENCHES,”A” JAIPUR
Before: DR. S. SEETHALAKSHMI, JM & SHRI RATHOD KAMLESH JAYANTBHAI, AM
These seven appeals are filed by the assessee, which was arised out of the order of the learned Commissioner of Income Tax (Appeals)-4, Jaipur all dated 31.10.2023 [Here in after referred as “ld. CIT(A)” ] for the assessment years 2012-13 to 2018-19 respectively, which in turn arise from the orders dated 20.12.2019 passed under section 143(3) r.w.s. 153Cof the Income Tax Act [Here in after referred as “Act” ], by th
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