ACIT v. Hirapanna Jewellers

128 Taxmann.com 291Income Tax Appellate Tribunal2021#1097 most cited

What is ACIT v. Hirapanna Jewellers authority for?

An abnormal increase in declared cash sales and deposits during demonetization does not warrant an addition under Section 68, as Section 68 applies to unexplained cash credits, not disclosed sales receipts supported by stock and purchases.

101

judgments rely on this decision, according to BharatTax’s citation analysis of 366,314 Indian tax judgments — from 2022 to 2026.

Also referred to as

ACIT v. Hirapanna Jewellers · Section 68 · cash sales demonetization · unexplained cash credit · sales receipts · rejection of books of account · stock matching · Section 115BBE · addition under section 68

Issues it is cited on

Judgments citing ACIT v. Hirapanna Jewellers

Zia Rathi, Delhi vs. Income Tax Officer Ward-44(3), Delhi

In the result, appeal filed by the assessee is allowed

ITA 1881/DEL/2024[2017-18]Status: DisposedITAT Delhi16 Jan 2026AY 2017-18

Bench: Shri Sudhir Kumar & Shri Manish Agarwalmrs. Zia Rathi, Income Tax Officer, 274, Dda Flats, Sector-1A, Ward-44(3), Dwarka Nasirpur, Vs. Delhi. New Delhi-110045. Pan-Bsvpr9218M (Appellant) (Respondent) Assessee By Dr. Rakesh Gupta, Adv. Shri Somil Agarwal, Adv. Shri Saksham Agarwal, Ca & Shri Deepesh Garg, Adv. Department By Ms. Ankush Kalra, Sr. Dr Date Of Hearing 04/11/2025 Date Of Pronouncement 16/01/2026 O R D E R Per Manish Agarwal, Am: This Appeal Is Filed By The Assessee Against The Order Of Learned Commissioner Of Income Tax, National Faceless Appeal Centre (Nfac), Delhi (‘Ld. Cit(A)’ In Short) Dated 27.02.2024 In Appeal No. Cit(A), Delhi- 15/11146/2019-20 Arising Out Of The Order Passed U/S 143(3) Of The Income Tax Act, 1961 (‘The Act’ For Short) For Assessment Year 2017-18. 2. Brief Facts Of The Case Are That Assessee Is Sole Proprietor Of M/S Veezee Traders Engaged In The Business Of Trading Of Pvc Coated Imported Fabric. The Zia Rathi Vs. Ito

Section 115BSection 142(1)Section 143(2)Section 143(3)Section 234BSection 68

…as reflected in trading account and it was held that if the opening stock, purchases, sales and closing stock have not been doubted and cash is received against such sales, then the addition cannot be said to be justified."  CIT v. Hirapanna Jewellers [2021] 96 ITR 24 (Vishakhapatnam-ITAT) "Where AO made addition under section 68 on account of huge cash amount deposited by assessee-jeweller in its bank account post demonetization, since assessee had explained source of said cash deposits as sales of jewellery, produced sale bills and admitted same as revenue receipt as well as offered it to tax and assessee also…

Gold Spice Impex, Delhi vs. Income Tax Officer, Ward-47(2), Delhi

In the result, the appeal filed by the assessee is partly allowed

ITA 2244/DEL/2024[2017-18]Status: DisposedITAT Delhi21 Nov 2025AY 2017-18

Bench: Shris.Rifaur Rahman & Shri Vimal Kumarm/S. Gold Spice Impex, Vs. Ito, Ward 47 (2), 1879, Kucha Chelian, Khari Boali, Delhi. Delhi – 110 006. (Pan : Aapfg0688P) (Appellant) (Respondent) Assessee By :Shri Rakesh Gupta, Advocate Shri Deepesh Garg, Advocate Revenue By : Shri Rajesh Kumar Dhanesta, Sr. Dr Date Of Hearing : 26.08.2025 Date Of Order : 21.11.2025 O R D E R Per S. Rifaur Rahman: 1. The Assessee Has Filed Appeal Against The Order Of The Learned Commissioner Of Income-Tax (Appeals)/National Faceless Appeal Centre (Nfac), Delhi [“Ld. Cit(A)”, For Short] Dated 17.01.2024 For The Assessment Year 2017-18 Raising Following Grounds Of Appeal :- “1. That Having Regard To The Facts & Circumstances Of The Case, Ld. Cit(A) Has Erred In Law & On Facts In Confirming The Action Of Ld. Ao In Making Aggregate Addition Of Rs.1,15,00,000/- On Account Of Cash Deposits U/S 68 & Taxing The Same U/S 115Bbe & That Too By Recording Incorrect Facts & Findings & Without Following The Principles Of Natural Justice.

For Appellant: Shri Rakesh Gupta, AdvocateFor Respondent: Shri Rajesh Kumar Dhanesta, Sr. DR
Section 115BSection 143(2)Section 234BSection 68

…as reflected in trading account and it was held that if the opening stock, purchases, sales and closing stock have not been doubted and cash is received against such sales, then the addition cannot be said to be justified.”  CIT v. Hirapanna Jewellers [2021] 96 ITR 24 ( Vishakhapatnam-ITAT) “ Where AO made addition under section 68 on account of huge cash amount deposited by assessee-jeweller in its bank account post demonetization, since assessee had explained source of said cash deposits as sales of jewellery, produced sale bills and admitted same as revenue receipt as well as offered it to tax and assessee al…

Sanjay Malhotra, New Delhi vs. ITO, Ward-29(3), Delhi

In the result, the appeal filed by the assessee is allowed

ITA 2255/DEL/2024[2017-18]Status: DisposedITAT Delhi13 Oct 2025AY 2017-18

Bench: Shri Satbeer Singh Godara & Shri S. Rifaur Rahmansanjay Malhotra, Vs. Ito, Ward 29 (3), Hs – 23, Second Floor, Kailash Colony, Delhi. New Delhi – 122 002. (Pan : Aaipm0514F) (Appellant) (Respondent) Assessee By : Shri K. Sampath, Advocate Shri V. Rajkumar, Advocate Revenue By : Shri Manish Gupta, Sr. Dr Date Of Hearing : 17.07.2025 Date Of Order : 13.10.2025 O R D E R Per S. Rifaur Rahman: 1. This Appeal Is Filed By The Assessee Against The Order Of The Ld. Commissioner Of Income-Tax (Appeals)/National Faceless Appeal Centre (Nfac), Delhi [For Short ‘Ld. Cit (A)] For The Assessment Year 2017-18. 2. Brief Facts Of The Case Are, Assessee Filed Its Return Of Income For Assessment Year 2017-18 On 27.10.2017 Declaring An Income Of Rs.15,06,840/-. The Case Was Selected For Complete Scrutiny Under Cass. Notices Under Section 143(2) & 142(1) Of The Income-Tax Act

For Appellant: Shri K. Sampath, AdvocateFor Respondent: Shri Manish Gupta, Sr. DR
Section 142(1)Section 143(2)

…serably failed to appreciate this aspect of the matter. 4.6 The essential features of cash deposits during the demonetization period have been lucidly and succinctly dealt with by the Vishakapatnam Bench of the Tribunal in ACIT vs. Hira Panna Jewellers (2021) 189 ITD 608. Being on similar facts this order is relied upon for relief in the subject case also. 4.7 According to the AO the deposits were to be added to the income of the Assessee u/s. 68 of the Act. The AO erred in failing to appreciate that Sec.68 of the Act applied to cash credits. It does not apply to sales receipts. Besides Sec.68 of the Act deems a…

ACIT v. Hirapanna Jewellers (128 Taxmann.com 291) — Cited in 101 Judgments | BharatTax