How many judgments cite CIT v. Padamchand Ramgopal?

40 judgments on BharatTax cite CIT v. Padamchand Ramgopal (76 ITR 719), spanning 2017 to 2025.

Which sections of the Income Tax Act does CIT v. Padamchand Ramgopal come up under?

It is most often cited in judgments turning on Section 143(3), Section 132, Section 132(1), Section 142(1), Section 143(2), Section 145(3).

CIT v. Padamchand Ramgopal

76 ITR 719Supreme Court of India1970#2963 most cited

What is CIT v. Padamchand Ramgopal authority for?

Minor irregularities in books of account cannot be the sole basis for rejection of the books or for making an estimated trading addition, especially when the assessee has provided explanations for discrepancies. The case distinguishes itself by focusing on receipts not brought into account rather than expenses claimed.

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2017 to 2025.

Also referred to as

CIT v. Padamchand Ramgopal · Padamchand Ramgopal · 76 ITR 719 · rejection of books of account · estimated income · minor irregularities · trading addition · section 145(3) · section 69b · section 145 · sundry creditors · section 44ab · section 131 · section 133a · scrutiny assessment · undisclosed income · speaking order · section 143(2) · section 132 · section 132(1) · 143(3) · 142(1) · 153A · 153C

Sections most often in play

Section 143(3)Section 132 Section 132(1)Section 142(1)Section 143(2)Section 145(3)Section 153A Section 153C

Issues it is cited on

rejection of books of account section 145(3)section 69b section 145 sundry creditors section 44ab section 131 section 133a scrutiny assessment undisclosed income speaking order section 143(2)

Judgments citing CIT v. Padamchand Ramgopal

MEDIBOYANA VENKATA APPALA SURYA PRAKASH,VISAKHAPATNAM vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-4(1), VISAKHAPATNAM

ITA 506/VIZ/2025[2015-16]Status: DisposedITAT Visakhapatnam26 Nov 2025AY 2015-16

Bench: Shri Ravish Sood & Shri Balakrishnan S.आ.अपी.सं /Ita No.506/Viz/2025 (िनधा"रण वष"/Assessment Year:2015-16) Mediboyana Venkata Appala Vs. Assistant Commissioner Surya Prakash, Of Income Tax, Visakhapatnam. Circle-4(1), Pan: Agnpm7780L Visakhapatnam. (Appellant) (Respondent) िनधा"रती "ारा/Assessee By: Shri Gvn Hari, Advocate राज" व "ारा/Revenue By: Dr. Aparna Villuri, Sr. Ar सुनवाई की तारीख/Date Of 19/11/2025 Hearing: घोषणा की तारीख/Date Of 26/11/2025 Pronouncement: आदेश / Order Per. Ravish Sood, Jm : The Present Appeal Filed By The Assessee Is Directed Against The Order Passed By The Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre, Delhi, Dated 17/06/2025, Which In Turn Arises From The Order Passed By The Assessing Officer Under Section 143(3) Of The Income Tax Act, 1961 (For Short, “The Act”), Dated 31/10/2017. The 2 Mediboyana Venkata Appala Surya Prakash Vs. Acit

For Appellant: Shri GVN Hari, AdvocateFor Respondent: Dr. Aparna Villuri, Sr. AR

Section 143(1)Section 143(2)Section 143(3)

…tead of rejecting the books of account and estimating income, the appellant himself accepted the discrepancies in claiming of expenses. The appellant has also relied upon the decision rendered by Hon'ble Supreme Court in the case of Padamchand Ramgopal (1970) 76 ITR 719. However, the facts of the referred case law is not applicable to the fact of appellant's case. The referred case law talks about the interest received and receipts not brought into account whereas in the present case the issue is related to the expenses claimed in the books of account. 6.2.3 In view of the above discussion, the action of AO in tr…

ASHIANA BUILDPROP PRIVATE LIMITED,UDAIPUR vs. DCIT, CENTRAL CIRCLE-1, UDIAPUR, UDAIPUR

ITA 709/JODH/2024[2016-17]Status: DisposedITAT Jodhpur26 May 2025AY 2016-17

Bench: DR. MITHA LAL MEENA (Accountant Member), DR. S. SEETHALAKSHMI (Judicial Member)

Section 132Section 145(3)Section 153ASection 234ASection 250

…at 957 (Cal) Minor irregularities cannot be made a basis of the rejection of the books of account or of trading addition. VIII. In this respect we also like to invite your attention towards the following judgments on the related issue: (a) Padampath Ramgopal 76 ITR 719 (SC). (b) ACIT VS M/S MOUNT MALT BRU LTD 34 TW 246 (Jp). (c) Manohar Lal V. ITO (2000) 68 TTJ 27 (JD) & (d) Shri Gautam Textile V. ITO (2001) 72 TTJ 169 (JD) (e) M/s Bansilal AbirchandSpg. &Wvg. Mills 75 ITR 260 (Bom) (Page 261) 4. Tax can be charged on real income not on notional income or notional profit: Against the addition we have also submit…

ASHIANA BUILDPROP PRIVATE LIMITED,UDAIPUR vs. DCIT, CENTRAL CIRCLE-1, UDAIPUR, UDAIPUR

ITA 706/JODH/2024[2013-14]Status: DisposedITAT Jodhpur26 May 2025AY 2013-14

Section 132Section 145(3)Section 153ASection 234ASection 250

…57 (Cal)\nMinor irregularities cannot be made a basis of the rejection of the books of account or\nof trading addition.\nVIII. In this respect we also like to invite your attention towards the following\njudgments on the related issue:\n(a) Padampath Ramgopal 76 ITR 719 (SC).\n(b) ACIT VS M/S MOUNT MALT BRU LTD 34 TW 246 (Jp).\n(c) Manohar Lal V. ITO (2000) 68 TTJ 27 (JD) &\n(d) Shri Gautam Textile V. ITO (2001) 72 TTJ 169 (JD)\n(e) M/s Bansilal AbirchandSpg. &Wvg. Mills 75 ITR 260 (Bom) (Page 261)\n4. Tax can be charged on real income not on notional income or notional profit:\nAgainst the addition we have also…

VISHAL BUILDERS, RAIPUR,RAIPUR vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-3(1), RAIPUR, RAIPUR

ITA 263/RPR/2023[2013-14]Status: DisposedITAT Raipur30 Nov 2023AY 2013-14

Bench: Shri Ravish Sood & Shri Arun Khodpiaआयकर अपील सं. / Ita No.263/Rpr/2023 "नधा"रण वष" / Assessment Year : 2013-14 Vishal Builders 7/619, Gawri Bhawan, Fafadih Naka, Raipur-492001(C.G.) Pan : Aaefv1401G .......अपीलाथ" / Appellant बनाम / V/S. The Assistant Commissioner Of Income Tax, Circle 3(1), Raipur, C.G.

For Appellant: Shri R.B Doshi, CAFor Respondent: Shri Satya Prakash Sharma, Sr. DR

Section 143(2)Section 143(3)Section 145(3)

…rs of Sec. 145(3) of the Act. Our aforesaid conviction that insignificant mistakes in accounts cannot lead to rejection of books of accounts u/s 145(3) is supported by the judgment of the Hon’ble Supreme Court in the case of CIT Vs. Padamchand Ramgopal (1970) 76 ITR 719 (SC). In its aforesaid order, it was, inter alia, observed by the Hon’ble Supreme Court that insignificant mistakes in the accounts cannot justify rejection of books of accounts of the assessee under Sec. 145(3) of the Act. Accordingly, in the backdrop of our aforesaid observations, we are of the considered view that in the absence of pointing out…

SHRI SHRI SHIV SHANKAR AGRAWAL,KORBA(CG) vs. THE INCOME TAX OFFICER-1, KORBA(CG)

In the result appeal of the assessee is partly allowed for statistical purposes, in terms of our observations herein above

ITA 270/BIL/2016[2008-09]Status: DisposedITAT Raipur24 Nov 2023AY 2008-09

Bench: Shri Ravish Sood, Jm & Shri Arun Khodpia, Am (Ita No. 270/Rpr/2016) (Assessment Year: 2008-09)

For Appellant: Shri Veekaas S Sharma, CAFor Respondent: Shri Satya Prakash Sharma, Sr. DR

Section 133ASection 143(3)

…ere from. 3.8 Reliance is placed on following judicial pronouncements in support of contention that rejection of books of accounts without pointing out specific defects is bad-in-law: S. Title Citation Authority CLC No. Reference 1. CIT vs. Padamchand (1970) 76 ITR 719 Supreme Court 29 to 30 of India Ramopal (SC) ACIT v s M/s 2. ITAT, Raipur Bench 31 to 50 Sanjay Agrawal CO No. 05/RPR/2018 ITA No. 3. ITAT, Raipur Bench 51 to 77 ACIT v s. M/s 42/RPR/2018 Radheshyam Agrawal 4. CIT vs. Om Overseas (2009) 315 ITR High Court of Punjab 78 to 80 185 & Haryana Dr. Prabhudayal vs. CIT (2018) 162 DTR High Court of 81 to…

KUNAN MAL KALU RAM JAIN AND COMPANY ,TONK vs. ITO,TONK, TONK

In the result, appeal of the assessee is allowed

ITA 70/JPR/2023[2018-19]Status: DisposedITAT Jaipur24 Aug 2023AY 2018-19

Bench: SHRI SANDEEP GOSAIN (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Sh. Mahendra Gargieya (Adv.) &For Respondent: Smt Monisha Choudhary (Addl. CIT)

Section 143(3)Section 234DSection 5

…of books of account maintained by the assessee." 8. Siddheshwari Cotton Mills P. Ltd. V CIT 117 ITR 953 at 957 (Cal) Minor irregularities cannot be made a basis of the rejection of the books of accounts or of trading addition. Kindly refer Padampath Ramgopal 76 ITR 719 (SC). Detailed reasons of low NP and GP were submitted before the ld. AO. The AO is factually incorrect to alleged that no expansion to this effect was filed in as much as vide letter dated 20.04.2022, para 3&4 (PB 5-6) this was fully explained. The same is reproduced hereunder. “3. Assessee has shown GP and NP as actual basis which was decrease a…

ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE 2(1), RAIPUR vs. PSA CONSTRUCTION, RAIPUR

In the result, appeal of the revenue is dismissed

ITA 145/RPR/2018[2015-16]Status: DisposedITAT Raipur17 Jul 2023AY 2015-16

Bench: SHRI RAVISH SOOD (Judicial Member), SHRI ARUN KHODPIA (Accountant Member)

For Respondent: Shri Piyush Tripathi, Sr. DR

Section 133ASection 145(3)Section 250(4)Section 253

…TR 356 Madhya Pradesh 5.1 No specific defect or discrepancy or infirmity pointed out in the books of accounts; books of accounts without pointing out specific defects is bad in law: Title Citation Authority s. CLC No. Reference 1. — CIT vs. Padamchand (1970) 76 ITR 719 Supreme Court Ramgopal (SC) of India 2. ACIT vs. M/s ITAT, Raipur — Sanjay Agrawal Bench ITA No. 82/RPR/ 2018 CO No. 05/ RPR/2018 3. ITA No. 42/RPR /2018 ITAT, Raipur -- Bench ACIT vs. M/s Radheshyam Agrawal 4. CIT vs. Om Overseas (2009) 315 ITR Page 1 185 High Court of Punjab & Haryana 5. Dr. Prabhudayal vs. (2018) 162 DTR 0012 High Court of Page…

DCIT 1(1), INDORE vs. M/S MAA UMIYA AGRITECH PVT. LTD. , INDORE

In the result, appeal of Revenue is dismissed

ITA 89/IND/2022[2012-13]Status: DisposedITAT Indore08 Jun 2023AY 2012-13

Bench: Shri Vijay Pal Rao & Shri B.M. Biyanidcit 1(1) M/S. Maa Umiya Agritech Pvt. Ltd. Indore 119, A.B. Road, Aloo Pyaj Mandi, Vs. Indore (Appellant / (Revenue) (Assessee) Pan: Aabcn8230F Revenue By Shri P.K. Mishra, Cit-Dr Respondent By Shri S.S. Solanki, Ar Date Of Hearing 11.04.2023 Date Of Pronouncement 08.06.2023

Section 12ASection 138Section 144Section 145

…t the assessee did not maintain quantitative records of Kher wood trees, and determined the sale of Kattha outside books by estimating yield at 14.13 per cent Not justified." (v) The Hon'ble Supreme Court in the case of CIT vs. Padamchand Ramgopal reported in 76 ITR 719 held that insignificant mistakes noticed in the books of account of one year, like one item of receipt having en incorrectly recorded, cannot form the basis for rejection of books of account. 14.3 The existence of books of account and relevant documents have not been disputed by the AO. When complete books of accounts are maintained and statutory…

AMAR SINGH SAHARAN,CHURU vs. ITO, WARD-2, CHURU

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

ITA 83/JODH/2020[2013-14]Status: DisposedITAT Jodhpur24 Mar 2023AY 2013-14

Bench: Shri Kul Bharatshri Manish Boradshri Amar Singh Saharan, Vs Ito, S/O-Shri Chimna Ram, Ward-2, Dhani-Asha, Tehsil- Churu Taranagar, Churu-331304. (Appellant) (Respondent) Pan No. Drbps4493E Assessee By Shri Suresh Ojha, Advocate Revenue By Shri S.M.Joshi, Jcit Dr Date Of Hearing 23/03/2023 Date Of 24/03/2023 Pronouncement

Section 147

…was justified in holding that since books of accounts had not been rejected, the mere fact that there had been a fall in the g.p. rate would not lead to the inference that the expenditure had been inflated. 6.3. In case of CIT vs. Padamchand Ram Gopal (1970) 76 ITR 719 (SC), the Hon'ble Supreme Court has held that no addition is justified if the books of accounts are not rejected. 6.4. We have also seen the other case law relied upon by the learned authorised representative and we find that the book results cannot be ignored if the books of accounts are not rejected or any defect were not pointed out by the AO.…

RAJ AUTO WHEELS (P) LTD.,JAIPUR vs. ACIT, AJMER

In the result, the appeal of the assessee is party allowed

ITA 929/JPR/2016[2009-10]Status: DisposedITAT Jaipur09 Nov 2022AY 2009-10

For Appellant: Shri Mahendra Gargieya, AdvocawteFor Respondent: Shri P.R. Meena, C IT-DR

Section 133(6)Section 143(3)Section 145(3)

…ubmissions separately. Hence kindly refer para 5 at Pg. 9-10 of this written submission. 4.Minor irregularities, even assuming were there, cannot be made a basis of the rejection of the books of accounts or of trading addition. Kindly refer Padampath Ramgopal 76 ITR 719 (SC). Thus, there was no valid basis at all to apply S. 145 of the Act in this case. Hence the same may please be quashed and the entire trading addition be deleted here itself. RAJ AUTO WHEELS (P) LTD. VS ACIT, CIRCLE-1, AJMER B. On merit: Alternatively, on merits also, there was no case with the AO to have made this addition, as submitted here…

M/S RAJ AUTO WHEELS P .LTD.,AJMER vs. JCIT, RANGE-1, AJMER

In the result, the appeal of the assessee is party allowed

ITA 397/JPR/2015[2011-12]Status: DisposedITAT Jaipur09 Nov 2022AY 2011-12

For Appellant: Shri Mahendra Gargieya, AdvocawteFor Respondent: Shri P.R. Meena, C IT-DR

Section 131Section 145(3)Section 194ASection 40

…arately. Hence kindly refer para 8.1 to 8.2 of this written submission at pg. 11 to 13. 4. Minor irregularities, even assuming were there, cannot be made a basis of the rejection of the books of accounts or of trading addition. Kindly refer Padampath Ramgopal 76 ITR 719 (SC). Thus, there was no valid basis at all to apply Sec. 145 in this case. Hence the same may please be quashed and the entire trading addition be deleted here itself. B. On merit: Alternatively, on merits also, there was no case with the AO to have made this addition, as submitted herein below: 1. Fair estimation required - Legal Position:1.1 In…

ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE-1(1), RAIPUR vs. M/S SANJAY AGRAWAL, RAIPUR

ITA 82/RPR/2018[2013-14]Status: DisposedITAT Raipur09 Jun 2022AY 2013-14

Bench: Shri Ravish Sood & Shri Rathod Kamlesh Jayantbhaiआयकर अपील सं. / Ita No. 82/Rpr/2018 Co No.05/Rpr/2018 "नधा"रण वष" / Assessment Year : 2013-14 The Assistant Commissioner Of Income Tax, Circle-1(1), Raipur (C.G.) .......अपीलाथ" / Appellant बनाम / V/S. M/S. Sanjay Agrawal 35-36, Millenium Plaza, G. E. Road, Raipur (C.G.) Pan : Aapfs0532E ……""यथ" / Respondent Assessee By : Shri Veekaas S. Sharma, Ar Revenue By : Shri G.N Singh, Dr सुनवाई क" तार"ख / Date Of Hearing : 24.05.2022 घोषणा क" तार"ख / Date Of Pronouncement : 09.06.2022

For Appellant: Shri Veekaas S. Sharma, ARFor Respondent: Shri G.N Singh, DR

Section 143(2)Section 143(3)Section 145

M/S. RAJ ENTERPRISE,,SURAT vs. THE DY. COMMISSIONER OF INCOME TAX-6,, SURAT

ITA 1167/AHD/2016[2010-11]Status: DisposedITAT Surat31 Mar 2022AY 2010-11

Bench: Shri Pawan Singh & Dr Arjun Lal Saini

Section 145(3)Section 254(1)Section 53A

…unts. The Raj Enterprises (AY 2009-10 & 2010-11) books of accounts were audited and the auditors have not given any adverse findings/ qualification. To support his submission, the ld. AR relied upon the following decision:  CIT Vs Padamchand Ramgopal (1970) 76 ITR 719 (SC).  CIT Vs Margadarsi Chit Funds (P) Ltd. (1985) 44 CTR (AP) 5  B. F. Varghese Vs State of Kerala (1969) 72 ITR 726 (Ker.) 29. Ground no. 2 which relates to estimation of rate of sale of plots at Rs.1,500/- per square yard. The ld. AR for the assessee submits that ld. CIT(A) after confirming the action of the Assessing Officer in rejection of…

M/S. RAJ ENTERPRISE,,SURAT vs. THE DY. COMMISSIONER OF INCOME TAX-6,, SURAT

ITA 1166/AHD/2016[2009-10]Status: DisposedITAT Surat31 Mar 2022AY 2009-10

Bench: Shri Pawan Singh & Dr Arjun Lal Saini

Section 145(3)Section 254(1)Section 53A

THE DY.COMMISSIONER OF INCOME TAX CIRCLE-2(3),, SURAT vs. M/S. RAJ ENTERPRISES,, SURAT

ITA 1164/AHD/2016[2010-11]Status: DisposedITAT Surat31 Mar 2022AY 2010-11

Bench: Shri Pawan Singh & Dr Arjun Lal Saini

Section 145(3)Section 254(1)Section 53A

INCOME TAX OFFICER, WARD-1-2, AJMER vs. SHRI BHAGCHAND JAIN, AJMER

In the result, appeal of the Revenue is dismissed and the cross objection of the assessee is partly allowed

ITA 1271/JPR/2018[2014-15]Status: DisposedITAT Jaipur10 Jan 2022AY 2014-15

For Appellant: Shri Mahendra Gargieya (Adv)For Respondent: Smt. Runi Pal (Addl.CIT-DR) fu/kZkfjrh dh vksj ls@

Section 145Section 145(3)

….145(3). 16 ITA 1271/JP/2018 & CO 42/JP/2018_ ITO Vs Sh. Bhagchand Jain 2.4 Alternatively, minor irregularities, even assuming were there, cannot be made a basis of the rejection of the books of account or of trading addition. Kindly refer Padampath Ramgopal 76 ITR 719 (SC). Thus, there was no valid basis at all to apply Sec. 145 in this case. Hence the same may please be quashed and in consequence thereof, the impugned addition of Rs. 19,61,344/- also deserves a complete deletion. 3.1. Fair estimation required - Legal Position: At the very outset, it is submitted that even invoking of S.145 does not confer blin…

SMT. MAMTA HALDIA,JAIPUR vs. DCIT, CIRCLE-1, JAIPUR

In the result, all the three appeals of the assessee are disposed off in light of aforesaid directions

ITA 1351/JPR/2019[2008-09]Status: DisposedITAT Jaipur27 Oct 2020AY 2008-09

For Appellant: Sh. M.L Borad (Advocate)For Respondent: Ms Chanchal Meena (JCIT)

Section 132Section 133ASection 139Section 143(2)Section 145Section 153A

…by AO. In any case, the rejection of books of accounts is also not justified especially when no significant defect has been pointed out by the AO. Reliance is placed on the judgment of Hon’ble Supreme Court in the case of CIT v/s. Padam Chand Ram Gopal (1970)76 ITR 719(S.C.). 10) In this line of business various qualities of precious and semi- precious stones are required and at the same time the assessee also requires different shapes and sizes of the stones and these are never available at one single place. Further the big dealers normally do not sell the goods in little volume. In these circumstances and to f…

SMT. MAMTA HALDIA,JAIPUR vs. DCIT, CIRCLE-1, JAIPUR

In the result, all the three appeals of the assessee are disposed off in light of aforesaid directions

ITA 1350/JPR/2019[2004-05]Status: DisposedITAT Jaipur27 Oct 2020AY 2004-05

For Appellant: Sh. M.L Borad (Advocate)For Respondent: Ms Chanchal Meena (JCIT)

Section 132Section 133ASection 139Section 143(2)Section 145Section 153A

SMT. MAMTA HALDIA,JAIPUR vs. DCIT, CIRCLE-1, JAIPUR

In the result, all the three appeals of the assessee are disposed off in light of aforesaid directions

ITA 1349/JPR/2019[2003-04]Status: DisposedITAT Jaipur27 Oct 2020AY 2003-04

For Appellant: Sh. M.L Borad (Advocate)For Respondent: Ms Chanchal Meena (JCIT)

Section 132Section 133ASection 139Section 143(2)Section 145Section 153A

THE ACIT RATLAM, RATLAM vs. ISHRI DEEPAK KUMAR SONI, RATLAM

In the result, appeal of the revenue’s stands dismissed

ITA 270/IND/2018[12-13]Status: DisposedITAT Indore01 Jun 2020

Bench: Hon'Ble Kul Bharat & Hon'Ble Manish Boradassessment Year 2012-13

Section 142(1)Section 143(3)Section 68Section 69C

…eems to base on an incorrect Item Movement Analysis sheet prepared by the Accountant and looking to the overall records maintained by the assessee this mistake seems to be insignificant. Hon’ble Apex Court in the case of CIT vs. Padamchand Ramgopal [1970] 76 ITR 719 held that “insignificant mistake cannot form basis for rejection of books of accounts.” Similarly Hon'ble’ Apex court in the case of Umacharan Show and Bros vs. CIT (1959) 37 ITR 271(SC) has observed that “there was no material on which the Income Tax Officer or the Appellate Tribunal could come to the conclusion that the firm was not genuine.…

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