R K INFRALINK LLP,RAJKOT vs. ACIT, CC-1, RAJKOT, RAJOKT

ITA 530/RJT/2024Status: DisposedITAT Rajkot24 February 2026AY 2021-22Bench: DR. ARJUN LAL SAINI (Accountant Member), DR. DINESH MOHAN SINHA (Judicial Member)21 pages
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What did the Tribunal hold?

The Tribunal held that the validity of the notice issued under Section 148 was a crucial issue. It also ruled that the benefit of telescoping should be provided to the assessee for cash loans given, as the confirmed unaccounted profit exceeded the loan amount.

What were the facts?

The assessee, R K Infralink LLP, is engaged in construction and faced assessment proceedings initiated under Section 147 of the Income Tax Act, 1961, following a search operation. The Assessing Officer made additions based on unaccounted 'on-money' receipts and cash loans given by the assessee.

What were the issues?

The key issues were the validity of proceedings initiated under Section 147 and the entitlement of the assessee to the benefit of telescoping for cash loans given against confirmed unaccounted profits.

Which sections of the Income-tax Act were involved?

Section 147,Section 148,Section 143(3),Section 115BBE,Section 69A

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Cases cited in this judgment(6)Show list

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Heard together (4 matters)

ITA No. 528/RJT/2024
ITA No. 529/RJT/2024
ITA No. 530/RJT/2024
ITA No. 531/RJT/2024

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

आयकर अपीलीय अिधकरण, राजकोट "ायपीठ, राजकोट। IN THE INCOME TAX APPELLATE TRIBUNAL, RAJKOT BENCH, RAJKOT BEFORE DR. ARJUN LAL SAINI, ACCOUNTANT MEMBER AND DR. DINESH MOHAN SINHA, JUDICIAL MEMBER आयकरअपीलसं./ITA No. 528/RJT/2024 (िनधा"रणवष"/Assessment Year: (2019-20) M/s. R K Infralink LLP The DCIT, CC-1, "ायीलेखासं./जीआइआरसं./PAN/GIR No.: AAXFR9975L (अपीलाथ"/Assessee) (""थ"/Respondent)

आयकरअपीलसं./ITA No. 529/RJT/2024 (िनधा"रणवष"/Assessment Year: (2020-21) M/s. R K Infralink LLP The DCIT, CC-1, "ायीलेखासं./जीआइआरसं./PAN/GIR No.: AAXFR9975L (अपीलाथ"/Assessee) (""थ"/Respondent)

आयकरअपीलसं./ITA No. 530/RJT/2024 (िनधा"रणवष"/Assessment Year: (2021-22) M/s. R K Infralink LLP The DCIT, CC-1, "ायीलेखासं./जीआइआरसं./PAN/GIR No.: AAXFR9975L (अपीलाथ"/Assessee) (""थ"/Respondent)

ITA No. 528-531 & 518-521/Rjt/2024 RK Infralink llp vs. The ACIT CC-1 Rjt आयकरअपीलसं./ITA No. 531/RJT/2024 (िनधा"र

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