Rajrani Kishanlal Pahwa, Surat vs. ITO, Ward 1(2)(1), Surat
In the result, the appeal of the assessee for AY 2009-10 is partly allowed
ITA 996/SRT/2025[2013-14]Status: HeardITAT Surat22 Jan 2026AY 2013-14
Bench: Dr. B.R.R. Kumar, Vice-Ms. Suchitra Kamble
For Appellant: Shri Suresh K. Kabra, CAFor Respondent: Shri Ajay Uke, Sr DR
Section 143(3)Section 147Section 148Section 250
…eceived, which were not deposited in the regular bank account, were deposited in the said account and there was no source of deposits other than trading activity. Reliance was placed on the decision of the Hon’ble Gujarat High Court in CIT v. Babulal K. Daga, 358 ITR 177 (Guj.), wherein it has been held that where the assessee has no other source of income and the deposits represent business turnover, only the embedded profit can be brought to tax. ITA Nos. 994 to 996/SRT/2025 Rajrani Kishanlal Pahwa Vs. ITO Asst. Year : 2009-10 , 2011-12, 2013-14 - 6– 11. In the present case, the assessee, in response to noti…