ITAT Rajkot Judgments — March 2026

The Tribunal held that while 'on-money' receipts were established, the estimation of profit by the lower authorities was excessive. The Tribunal directed that the profit on 'on-money' should be taxed at 10%.

The Tribunal considered grounds related to the validity of notices issued under section 148, additions made based on estimated profits, and the year of taxation for on-money receipts. The appeals were consolidated due to common issues.

The Tribunal considered grounds related to the validity of notices issued under section 148, additions made based on estimated profits, and the year of taxation for on-money receipts. The appeals were consolidated due to common issues.

The Tribunal considered grounds related to the validity of notices issued under section 148, additions made based on estimated profits, and the year of taxation for on-money receipts. The appeals were consolidated due to common issues.

The Tribunal held that while 'on-money' receipts were established, the estimation of profit by the lower authorities was excessive. The Tribunal directed that the profit on 'on-money' should be taxed at 10%.

The Tribunal considered grounds related to the validity of reassessment proceedings initiated under Section 147 and the correctness of the 'on-money' additions. The Tribunal also addressed the timing of taxation for such income, whether in the year of receipt or sale deed execution.

The tribunal acknowledged that many grounds were academic or contentious. It focused on the primary grievances, including the validity of Section 148 notices and reassessments initiated under Section 147. The tribunal also considered the CIT(A)'s directions regarding the year of taxation for unaccounted profits.

The tribunal acknowledged that many grounds were academic or contentious. It focused on the primary grievances, including the validity of Section 148 notices and reassessments initiated under Section 147. The tribunal also considered the CIT(A)'s directions regarding the year of taxation for unaccounted profits.

The tribunal acknowledged that many grounds were academic or contentious. It focused on the primary grievances, including the validity of Section 148 notices and reassessments initiated under Section 147. The tribunal also considered the CIT(A)'s directions regarding the year of taxation for unaccounted profits.

The tribunal acknowledged that many grounds were academic or contentious. It focused on the primary grievances, including the validity of Section 148 notices and reassessments initiated under Section 147. The tribunal also considered the CIT(A)'s directions regarding the year of taxation for unaccounted profits.

The tribunal acknowledged that many grounds were academic or contentious. It focused on the primary grievances, including the validity of Section 148 notices and reassessments initiated under Section 147. The tribunal also considered the CIT(A)'s directions regarding the year of taxation for unaccounted profits.

The Tribunal held that the estimation of profit on 'on-money' by the lower authorities was excessive. It directed the Assessing Officer to make additions at a rate of 10% on the 'on-money', considering the business nature and past performance.

The Tribunal held that the estimation of profit on 'on-money' by the lower authorities was excessive. It directed the Assessing Officer to make additions at a rate of 10% on the 'on-money', considering the business nature and past performance.

The Tribunal held that the estimation of profit on 'on-money' by the lower authorities was excessive. It directed the Assessing Officer to make additions at a rate of 10% on the 'on-money', considering the business nature and past performance.

The Tribunal noted that the CIT(A) deleted the protective addition because the substantive addition in the firm's hands was also deleted. However, the Tribunal decided to set aside the matter and restore it to the AO to verify if the amount of Rs. 1,84,99,937/- was indeed added in the hands of Titanium Buildcon LLP and to adjudicate the matter according to law after giving the assessee an opportunity to be heard.

The tribunal noted that most grounds raised by both parties were either academic or contentious. The primary dispute revolves around the AO's confirmation of unaccounted receipts and the estimation of profits at 16%, as well as the year of taxation for 'on-money' receipts. The tribunal has consolidated multiple appeals due to common issues.

The tribunal held that the CIT(A) did not decide the appeal as per Section 250(6) and that principles of natural justice require providing sufficient opportunity of being heard. Therefore, the tribunal set aside the CIT(A)'s order and remitted the matter back for fresh adjudication after giving the assessee due opportunity.

The Tribunal noted the assessee's claim of non-compliance due to wrong advice and decided to grant one more opportunity. The matter was restored to the AO to re-adjudicate after allowing the assessee to present further evidence and be heard.

The tribunal noted that most grounds raised by both parties were either academic or contentious. The primary dispute revolves around the AO's confirmation of unaccounted receipts and the estimation of profits at 16%, as well as the year of taxation for 'on-money' receipts. The tribunal has consolidated multiple appeals due to common issues.

The tribunal noted that most grounds raised by both parties were either academic or contentious. The primary dispute revolves around the AO's confirmation of unaccounted receipts and the estimation of profits at 16%, as well as the year of taxation for 'on-money' receipts. The tribunal has consolidated multiple appeals due to common issues.

The tribunal noted that most grounds raised by both parties were either academic or contentious. The primary dispute revolves around the AO's confirmation of unaccounted receipts and the estimation of profits at 16%, as well as the year of taxation for 'on-money' receipts. The tribunal has consolidated multiple appeals due to common issues.

The Tribunal acknowledged that the assessee had raised multiple grounds of appeal, but focused on the core grievances. Key among these were the validity of the notice issued under section 148, which the assessee argued rendered the reassessment proceedings invalid, and the addition made by estimating profit at 16% of on-money receipts, which the assessee contended was bad in law and excessive.

The tribunal noted that most grounds raised by both parties were either academic or contentious. The primary dispute revolves around the AO's confirmation of unaccounted receipts and the estimation of profits at 16%, as well as the year of taxation for 'on-money' receipts. The tribunal has consolidated multiple appeals due to common issues.

The tribunal acknowledged that many grounds were academic or contentious. It focused on the primary grievances, including the validity of Section 148 notices and reassessments initiated under Section 147. The tribunal also considered the CIT(A)'s directions regarding the year of taxation for unaccounted profits.

The tribunal acknowledged that many grounds were academic or contentious. It focused on the primary grievances, including the validity of Section 148 notices and reassessments initiated under Section 147. The tribunal also considered the CIT(A)'s directions regarding the year of taxation for unaccounted profits.

The Tribunal considered grounds related to the validity of reassessment proceedings initiated under Section 147 and the correctness of the 'on-money' additions. The Tribunal also addressed the timing of taxation for such income, whether in the year of receipt or sale deed execution.

The Tribunal considered grounds related to the validity of reassessment proceedings initiated under Section 147 and the correctness of the 'on-money' additions. The Tribunal also addressed the timing of taxation for such income, whether in the year of receipt or sale deed execution.

The Tribunal held that while 'on-money' receipts are taxable, the estimation of profit by the CIT(A) at 16% was too high. Following jurisdictional High Court precedents and the assessee's average profit, the Tribunal directed the addition to be made at 10% of the 'on-money'.

The tribunal noted that most grounds raised by both parties were either academic or contentious. The primary dispute revolves around the AO's confirmation of unaccounted receipts and the estimation of profits at 16%, as well as the year of taxation for 'on-money' receipts. The tribunal has consolidated multiple appeals due to common issues.

The Tribunal noted that the CIT(A) deleted the protective addition because the substantive addition in the firm's hands was also deleted. However, the Tribunal decided to set aside the matter and restore it to the AO to verify if the amount of Rs. 1,84,99,937/- was indeed added in the hands of Titanium Buildcon LLP and to adjudicate the matter according to law after giving the assessee an opportunity to be heard.

The Tribunal held that the estimation of profit on 'on-money' by the lower authorities was excessive. It directed the Assessing Officer to make additions at a rate of 10% on the 'on-money', considering the business nature and past performance.

The Tribunal held that the estimation of profit on 'on-money' by the lower authorities was excessive. It directed the Assessing Officer to make additions at a rate of 10% on the 'on-money', considering the business nature and past performance.

The Tribunal found some merit in the assessee's submissions regarding the source of funds and directed the AO to make an ad-hoc addition of Rs. 6,40,000 (10% of Rs. 64,00,000) to cover inconsistencies, applying normal income tax rates instead of Section 115BBE.

The Tribunal noted the assessee's negligence in pursuing the case before both the AO and the Ld. CIT(A). It directed the assessee to deposit a cost of Rs. 5,000 with the Prime Minister Relief Fund within 10 days and granted another opportunity for the assessee to represent its case before the lower authority.

The tribunal acknowledged that many grounds were academic or contentious. It focused on the primary grievances, including the validity of Section 148 notices and reassessments initiated under Section 147. The tribunal also considered the CIT(A)'s directions regarding the year of taxation for unaccounted profits.

The tribunal acknowledged that many grounds were academic or contentious. It focused on the primary grievances, including the validity of Section 148 notices and reassessments initiated under Section 147. The tribunal also considered the CIT(A)'s directions regarding the year of taxation for unaccounted profits.

The tribunal acknowledged that many grounds were academic or contentious. It focused on the primary grievances, including the validity of Section 148 notices and reassessments initiated under Section 147. The tribunal also considered the CIT(A)'s directions regarding the year of taxation for unaccounted profits.

The Tribunal acknowledged that the assessee had raised multiple grounds of appeal, but focused on the core grievances. Key among these were the validity of the notice issued under section 148, which the assessee argued rendered the reassessment proceedings invalid, and the addition made by estimating profit at 16% of on-money receipts, which the assessee contended was bad in law and excessive.

The Tribunal acknowledged that the assessee had raised multiple grounds of appeal, but focused on the core grievances. Key among these were the validity of the notice issued under section 148, which the assessee argued rendered the reassessment proceedings invalid, and the addition made by estimating profit at 16% of on-money receipts, which the assessee contended was bad in law and excessive.

The Tribunal acknowledged that the assessee had raised multiple grounds of appeal, but focused on the core grievances. Key among these were the validity of the notice issued under section 148, which the assessee argued rendered the reassessment proceedings invalid, and the addition made by estimating profit at 16% of on-money receipts, which the assessee contended was bad in law and excessive.

The Tribunal acknowledged that the assessee had raised multiple grounds of appeal, but focused on the core grievances. Key among these were the validity of the notice issued under section 148, which the assessee argued rendered the reassessment proceedings invalid, and the addition made by estimating profit at 16% of on-money receipts, which the assessee contended was bad in law and excessive.

The Tribunal held that while 'on-money' receipts are taxable, the estimation of profit by the CIT(A) at 16% was too high. Following jurisdictional High Court precedents and the assessee's average profit, the Tribunal directed the addition to be made at 10% of the 'on-money'.

The Tribunal held that while 'on-money' receipts are taxable, the estimation of profit by the CIT(A) at 16% was too high. Following jurisdictional High Court precedents and the assessee's average profit, the Tribunal directed the addition to be made at 10% of the 'on-money'.

The Tribunal considered grounds related to the validity of reassessment proceedings initiated under Section 147 and the correctness of the 'on-money' additions. The Tribunal also addressed the timing of taxation for such income, whether in the year of receipt or sale deed execution.

The Tribunal considered grounds related to the validity of reassessment proceedings initiated under Section 147 and the correctness of the 'on-money' additions. The Tribunal also addressed the timing of taxation for such income, whether in the year of receipt or sale deed execution.

The Tribunal considered grounds related to the validity of reassessment proceedings initiated under Section 147 and the correctness of the 'on-money' additions. The Tribunal also addressed the timing of taxation for such income, whether in the year of receipt or sale deed execution.