ITAT Rajkot Judgments — February 2026

The tribunal noted that the issues involved in the cross-appeals were common and identical. It focused on the core grievances, including the validity of the reassessment under Section 147, the estimation of profit at 16%, and the year of taxation for unaccounted 'on-money' receipts. The Ld. CIT(A) had confirmed the AO's action regarding the reassessment and profit estimation, but directed the AO to tax the unaccounted profit in the year of sale deed execution.

The tribunal held that only the profit element embedded in the gross 'on-money' receipts should be taxed, not the entire receipts. It referenced High Court judgments that estimated profit at 6% to 8% in similar cases for real estate developers.

The tribunal held that only the profit element embedded in the gross 'on-money' receipts should be taxed, not the entire receipts. It referenced High Court judgments that estimated profit at 6% to 8% in similar cases for real estate developers. The tribunal did not explicitly state its own estimated profit rate but affirmed the principle of taxing only the profit component.

The tribunal consolidated cross-appeals from both the assessee and the revenue, noting common and identical issues. The core dispute revolved around the confirmation of the reassessment and the estimation of profit at 16% on unaccounted receipts. The Ld. CIT(A) directed the AO to tax the unaccounted profit in the year the sale deed was executed, rather than the year the 'on-money' was received.

The tribunal held that only the profit element embedded in the gross 'on-money' receipts should be taxed, not the entire receipts. It referred to High Court judgments suggesting a profit estimation rate of 6% to 8% for such undisclosed receipts in real estate.

The tribunal held that only the profit element embedded in the gross 'on-money' receipts should be taxed, not the entire receipts. It referred to High Court judgments suggesting a profit estimation rate of 6% to 8% for such undisclosed receipts in real estate.

The tribunal held that only the profit element embedded in the 'on-money' receipts should be taxed, not the entire receipts. The AO's action of estimating profit after invoking Section 145(3) was upheld, aligning with the principle that tax is on income, not gross receipts.

The tribunal consolidated cross-appeals from both the assessee and the revenue, noting common and identical issues. The core controversy revolved around the confirmation of the Assessing Officer's action under Section 147 and the estimation of profit at 16% on the unaccounted receipts. The Ld. CIT(A) had directed the AO to tax the unaccounted profit in the year of sale deed execution, which the revenue contested.

The tribunal is hearing cross-appeals from both the assessee and the revenue. The core issues revolve around the validity of the reassessment under Section 147, the estimated profit rate of 16% on unaccounted income, and the year in which the unaccounted profit should be taxed (year of receipt vs. year of sale deed execution). The tribunal will dispose of these appeals through a consolidated order.

The tribunal consolidated cross-appeals from both the assessee and the revenue, noting common and identical issues. The core of the controversy revolved around the confirmation of the Assessing Officer's action under Section 147 and the estimation of profit at 16% on the unaccounted receipts. The tribunal also addressed the revenue's contention regarding the year of taxation for the unaccounted profit.

The tribunal held that only the profit element embedded in the unaccounted 'on-money' receipts should be taxed, not the entire receipts. It also directed the AO to tax the unaccounted profit in the year the sale deed is executed, aligning with accounting principles for real estate developers, rather than the year the 'on-money' was received.

The tribunal consolidated cross-appeals from both the assessee and the revenue, noting common and identical issues. The core of the controversy revolved around the confirmation of the Assessing Officer's action regarding the reassessment and the estimation of profit on the unaccounted income. The tribunal decided to address the main grievances of both parties.

The tribunal held that only the profit element embedded in the 'on-money' receipts should be taxed, not the entire receipts. It noted that the Assessing Officer had correctly invoked Section 145(3) and proceeded to estimate the profit.

The tribunal held that only the profit element embedded in the gross 'on-money' receipts should be taxed, not the entire receipts. It referred to High Court judgments suggesting profit estimation rates of 6% to 8% for such undisclosed receipts in real estate.

The tribunal held that only the profit element embedded in the 'on-money' receipts should be taxed, not the entire receipts. The AO's estimation of profit at 24% was deemed excessive, and the tribunal referred to High Court judgments suggesting a profit rate of 6% to 8%.

The tribunal consolidated cross-appeals from both the assessee and the revenue, noting common and identical issues. The core controversy revolved around the assessment of unaccounted profit from 'on-money' receipts and the appropriate year for taxation of such income, particularly concerning the estimated profit rate and the timing of income recognition.

The tribunal held that only the profit element embedded in the gross 'on-money' receipts should be taxed, not the entire receipts. It referred to High Court judgments that estimated profit at 6% to 8% in similar cases for real estate developers. The tribunal also addressed the timing of taxation for unaccounted profit, directing it to be taxed in the year the sale deed is executed, aligning with ICDS-3.

The tribunal held that only the profit element embedded in the 'on-money' receipts should be taxed, not the entire receipts. It noted that various High Courts and ITATs have estimated this profit element between 6% and 8%. The tribunal did not specify the exact percentage applied but affirmed the principle of taxing only the profit component.

The tribunal held that only the profit element embedded in the gross 'on-money' receipts should be taxed, not the entire receipts. It referred to High Court judgments suggesting a profit estimation rate of 6% to 8% for such undisclosed receipts in real estate.

The tribunal consolidated five appeals, three by the assessee and two by the revenue, due to common issues. The core issues revolve around the validity of the reassessment notice, the addition of 'on-money' receipts, the year of taxability for unaccounted profit, and the deletion of additions for unaccounted expenses. The tribunal will address these specific grievances.

The tribunal consolidated five appeals, three by the assessee and two by the revenue, due to common and identical issues. The core issues revolve around the validity of the notice issued under Section 148, the estimation of profit on 'on-money' receipts, the year of taxation for unaccounted profit, and the deletion of additions for unaccounted expenses under Section 69C read with Section 115BBE.

The tribunal consolidated five appeals (three by the assessee, two by the revenue) due to common issues. The core issues revolved around the validity of the reassessment notice, the addition of 'on-money' receipts as estimated profit, and the treatment of unaccounted expenses. The specific outcome for each ground is not detailed in the provided text, but the tribunal aimed to address the main grievances.

The tribunal consolidated five appeals (three by the assessee, two by the revenue) due to common issues. The core issues revolved around the validity of the reassessment notice, the addition of 'on-money' receipts, the estimation of profit, the year of taxability for unaccounted profit, and the deletion of additions for unaccounted expenses. The tribunal will address these specific grounds.

The tribunal consolidated five appeals (three by the assessee, two by the revenue) due to common issues. The core issues revolved around the validity of the reassessment notice, the addition of 'on-money' receipts, the estimation of profit, and the treatment of unaccounted expenses. The specific outcome for each ground is not detailed in the provided text, but the tribunal aimed to address the main grievances.

The tribunal will decide on the validity of the reassessment proceedings initiated under Section 147/148 and the merits of the additions made by estimating profit on 'on-money' receipts. The assessee challenges both the legal validity of the notice and the quantum of the addition.

The tribunal upheld the validity of the reassessment proceedings initiated under Section 147, noting that the search was conducted after April 1, 2021, which allows for deemed satisfaction for three assessment years prior to the search. The tribunal dismissed the assessee's grounds challenging the validity of the Section 148 notice.

The tribunal dismissed the assessee's appeal regarding the validity of the reassessment proceedings, confirming that the notice under Section 148 was validly issued due to tangible material found during the search and the amended provisions for search assessments. The tribunal upheld the CIT(A)'s decision on the validity of the reassessment.

The tribunal's decision is not explicitly stated in the provided text, as the judgment only outlines the facts and grounds of appeal. Therefore, it is not possible to determine what the tribunal decided based on this excerpt.

The tribunal upheld the validity of the reassessment proceedings initiated under Section 147, noting that the search was conducted after April 1, 2021, which allows for deemed satisfaction for three assessment years prior to the search. The tribunal dismissed the assessee's grounds challenging the validity of the Section 148 notice and confirmed the CIT(A)'s findings.

The tribunal will decide on the validity of the reassessment proceedings initiated under Section 147/148 and the merits of the additions made by estimating profit at 16% of the 'on-money' receipts. The assessee challenges both the legal validity of the notice and the quantum of the addition.

The ITAT upheld the validity of the reassessment proceedings initiated under Section 147, noting that the search was conducted after April 1, 2021, which provides for deemed satisfaction for three assessment years prior to the search date. The tribunal dismissed the assessee's grounds challenging the reassessment's validity.

The tribunal will decide on the validity of the Section 148 notice for initiating reassessment proceedings and the sustenance or reduction of the addition made by estimating profit at 16% of the 'on-money' receipts. The Ld. CIT(A) had dismissed the appeal regarding the validity of the notice and retained the addition.

The tribunal will decide on the validity of the Section 148 notice for initiating reassessment proceedings and the sustenance of the addition made by estimating profit at 16% of the 'on-money' receipts. The Ld. CIT(A) had dismissed the appeal regarding the validity of the notice and retained the addition.

The tribunal will decide on the validity of the Section 148 notice for initiating reassessment proceedings and the merits of the addition made by estimating profit at 16% of the 'on-money' receipts. The Ld. CIT(A) had dismissed the appeal regarding the validity of the notice and retained the addition.

The tribunal will decide on the validity of the Section 148 notice for initiating reassessment proceedings and the merits of the addition made by estimating profit at 16% of the 'on-money' receipts. The Ld. CIT(A) had dismissed the appeal regarding the validity of the notice and retained the addition.

The tribunal upheld the validity of the reassessment proceedings initiated under Section 147, noting that the search was conducted after April 1, 2021, which allows for deemed satisfaction for three assessment years prior to the search. The tribunal dismissed the assessee's grounds challenging the reassessment's validity.

The tribunal dismissed the assessee's challenge to the validity of the reassessment proceedings, affirming that the search conducted after April 1, 2021, provided deemed satisfaction for issuing notice under Section 148 for three prior assessment years. The tribunal confirmed the CIT(A)'s finding that the reassessment was valid.

The ITAT upheld the validity of the reassessment proceedings initiated under Section 147, noting that the search was conducted after April 1, 2021, which provides for deemed satisfaction for three assessment years prior to the search date. The tribunal dismissed the assessee's grounds challenging the reassessment's validity.

The ITAT upheld the validity of the reassessment proceedings initiated under Section 147, noting that the search was conducted after April 1, 2021, which allows for deemed satisfaction for three assessment years prior to the search date. The tribunal dismissed the assessee's grounds challenging the reassessment's validity.

The tribunal will address the validity of the reassessment notice, the estimation of profit on 'on-money' receipts, the year of taxability for unaccounted profit, and the deletion of additions for unaccounted expenses. The specific outcome for each issue will be determined after considering the arguments.

The tribunal consolidated 19 appeals from both the assessee and the Revenue, addressing common issues. The core controversies revolved around the validity of Section 148 notices, the estimation of profit on 'on-money' receipts, additions related to negative cash balances, and the year of taxability for unaccounted profits. The specific outcomes for each ground were not detailed in the provided text, but the tribunal aimed to resolve the main grievances.

The tribunal consolidated 19 appeals from both the assessee and the Revenue, noting common and identical issues. The core issues revolved around the validity of Section 148 notices, additions made for estimated profit on 'on-money' receipts, alleged negative cash balances, unexplained money under Section 69A, and short-term capital gains. The tribunal decided to address these core grievances.

The tribunal consolidated 19 appeals from both the assessee and the Revenue, noting common and identical issues. The core issues revolved around the validity of Section 148 notices, the estimation of profit on 'on-money' receipts, additions for negative cash balances, and unexplained money under Section 69A. The tribunal will address these specific grievances.

The tribunal consolidated 19 appeals from both the assessee and the revenue, noting common and identical issues. The core issues revolved around the validity of Section 148 notices, additions made for estimated 'on-money' receipts, negative cash balances, unexplained money, and short-term capital gains. The tribunal decided to address the main grievances of both parties.

The tribunal will address the validity of the reassessment notice, the estimation of profit on 'on-money' receipts, the year of taxability for unaccounted profit, and the deletion of additions for unaccounted expenses. The specific outcome for each issue will be determined after further deliberation.

The tribunal heard a bunch of 19 appeals, consolidating them due to common and identical issues. The core issues revolved around the validity of reassessment notices, estimation of profit on 'on-money' receipts, additions for negative cash balances, and unexplained money. The specific outcomes for each ground of appeal were not detailed in the provided text, but the tribunal aimed to address the main grievances.

The tribunal will address the validity of the reassessment notice, the estimation of profit on 'on-money' receipts, the year of taxability for unaccounted profit, and the deletion of additions for unaccounted expenses. The specific outcome for each issue will be determined after further deliberation.

The tribunal consolidated 19 appeals from both the assessee and the Revenue, noting common and identical issues. The core issues revolved around the validity of Section 148 notices, the estimation of profit on 'on-money' receipts, additions for negative cash balances, and unexplained money. The tribunal's specific decisions on each ground are not detailed in the provided text, but it indicates a comprehensive review of the validity of proceedings and the quantum of additions.

The tribunal consolidated 19 appeals due to common issues. The core issues revolve around the validity of reassessment notices, additions made for estimated profit on 'on-money' receipts, alleged negative cash balances, unexplained money, and short-term capital gains. The tribunal will address these specific grievances.

The tribunal consolidated 19 appeals from both the assessee and the revenue, focusing on the validity of reassessment notices, additions for estimated 'on-money' profit, negative cash balances, unexplained money, and short-term capital gains. The specific outcomes for each ground were not detailed in the provided text, but the tribunal aimed to address the core grievances.