CIT v. Piara Singh

124 ITR 40Supreme Court of India1980#1187 most cited

What is CIT v. Piara Singh authority for?

When dealing with unaccounted transactions of purchase and sale, including those from an illegal business, only the profit or income earned from such sales can be assessed as undisclosed income and subjected to tax, not the entire sale proceeds.

95

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2006 to 2026.

Also referred to as

Piara Singh SC 1980 · 124 ITR 40 · unaccounted sales · undisclosed income · illegal business income · profit from unrecorded transactions · entire sale cannot be taxed · only profit taxable · section 145(3) · rejection of books of account

Also reported as

3 Taxmann 67

Sections most often in play

Section 147Section 148Section 143(3)Section 145(3)Section 133ASection 142(1)Section 132Section 143(2)

Issues it is cited on

on money receiptsection 145(2)project completion methodsection 199rejection of books of accounticdson-moneyreasoned orderspecified authorityloose paperssection 145(3)approval under section 151

Judgments citing CIT v. Piara Singh

DCIT, CENTRAL CIRCLE 1, RAJKOT, RAJKOT vs. SHRI DEEPAK MOHANLAL PURSWANI, RAJKOT

ITA 665/RJT/2024[2022-23]Status: DisposedITAT Rajkot13 Mar 2026AY 2022-23
For Appellant: Shri Mehul Ranpura, Ld. ARFor Respondent: Shri Abhimanyu Singh Yadav, Ld. SR. DR
Section 143(3)Section 147Section 250

…unaccounted transaction of purchase and sale only profit/ income on sales could\nbe assessed as undisclosed income and could be subjected to tax. Case laws to\nthe point are as under: 1. Dr. T.A. Quereshi (157 taxmann.com 514) (Supreme\nCourt) 2. Piara Singh (124 ITR 40) (Supreme Court) 3. S.C. Kothari (82 ITR\n794 (Supreme Court) 23.5 The assessee admitted such profit at Rs.45,00,000/-\nand disclosed that on said transactions income in PMGKY, 2016 and paid due\ntax thereon. The copy of certificate issued by PCIT is placed on record. Thus\nwhen that transactions are of unrecorded purchase and sale of gold, which…

DCIT, CENTRAL CIRCLE 1, RAJKOT, RAJKOT vs. YAGNIK ROAD HIGHSTREET LLP, RAJKOT

Appeal of the revenue is dismissed:\n(i)Ground no

ITA 684/RJT/2024[2021-22]Status: DisposedITAT Rajkot12 Mar 2026AY 2021-22
For Appellant: Shri D.M. Rindani, Ld.ARFor Respondent: Shri Sanjay Punglia, Ld. CIT(DR)
Section 143(3)Section 147

…unaccounted transaction of purchase and sale only profit/ income on sales could\nbe assessed as undisclosed income and could be subjected to tax. Case laws to\nthe point are as under: 1. Dr. T.A. Quereshi (157 taxmann.com 514) (Supreme\nCourt) 2. Piara Singh (124 ITR 40) (Supreme Court) 3. S.C. Kothari (82 ITR\n794 (Supreme Court) 23.5 The assessee admitted such profit at Rs.45,00,000/-\nand disclosed that on said transactions income in PMGKY, 2016 and paid due\ntax thereon. The copy of certificate issued by PCIT is placed on record. Thus\nwhen that transactions are of unrecorded purchase and sale of gold, which…

YAGNIK ROAD HIGHSTREET LLP,RAJKOT vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL -1,, RAJKOT

Appeal of the revenue is dismissed:\n(i)Ground no

ITA 512/RJT/2024[2021-22]Status: DisposedITAT Rajkot12 Mar 2026AY 2021-22
For Appellant: Shri D.M. Rindani, Ld.ARFor Respondent: Shri Sanjay Punglia, Ld. CIT(DR)
Section 143(3)Section 147

…unaccounted transaction of purchase and sale only profit/ income on sales could\nbe assessed as undisclosed income and could be subjected to tax. Case laws to\nthe point are as under: 1. Dr. T.A. Quereshi (157 taxmann.com 514) (Supreme\nCourt) 2. Piara Singh (124 ITR 40) (Supreme Court) 3. S.C. Kothari (82 ITR\n794 (Supreme Court) 23.5 The assessee admitted such profit at Rs.45,00,000/-\nand disclosed that on said transactions income in PMGKY, 2016 and paid due\ntax thereon. The copy of certificate issued by PCIT is placed on record. Thus\nwhen that transactions are of unrecorded purchase and sale of gold, which…

YAGNIK ROAD HIGHSTREET LLP,RAJKOT vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL -1,, RAJKOT

Appeal of the revenue is dismissed:\n(i)Ground no

ITA 511/RJT/2024[2020-21]Status: DisposedITAT Rajkot12 Mar 2026AY 2020-21
For Appellant: Shri D.M. Rindani, Ld.ARFor Respondent: Shri Sanjay Punglia, Ld. CIT(DR)
Section 143(3)Section 147

…unaccounted transaction of purchase and sale only profit/ income on sales could\nbe assessed as undisclosed income and could be subjected to tax. Case laws to\nthe point are as under: 1. Dr. T.A. Quereshi (157 taxmann.com 514) (Supreme\nCourt) 2. Piara Singh (124 ITR 40) (Supreme Court) 3. S.C. Kothari (82 ITR\n794 (Supreme Court) 23.5 The assessee admitted such profit at Rs.45,00,000/-.\nand disclosed that on said transactions income in PMGKY, 2016 and paid due\ntax thereon. The copy of certificate issued by PCIT is placed on record. Thus\nwhen that transactions are of unrecorded purchase and sale of gold, which…

SIX TWENTY REALTY PVT LTD,RAJOT vs. DCIT, CC-1, RAJKOT, RAJKOT

ITA 787/RJT/2024[2020-21]Status: DisposedITAT Rajkot11 Mar 2026AY 2020-21
Section 133ASection 143(3)Section 147Section 148Section 250

…unaccounted transaction of purchase and sale only profit/ income on sales could\nbe assessed as undisclosed income and could be subjected to tax. Case laws to\nthe point are as under: 1. Dr. T.A. Quereshi (157 taxmann.com 514) (Supreme\nCourt) 2. Piara Singh (124 ITR 40) (Supreme Court) 3. S.C. Kothari (82 ITR\n794 (Supreme Court) 23.5 The assessee admitted such profit at Rs.45,00,000/-\nand disclosed that on said transactions income in PMGKY, 2016 and paid due\ntax thereon. The copy of certificate issued by PCIT is placed on record. Thus\nwhen that transactions are of unrecorded purchase and sale of gold, which…

SIX TWENTY REALTY PVT. LTD.,RAJKOT vs. DCIT, CC-1, RAJKOT, RAJKOT

ITA 786/RJT/2024[2019-20]Status: DisposedITAT Rajkot11 Mar 2026AY 2019-20
Section 133ASection 143(3)Section 147Section 148Section 250

…unaccounted transaction of purchase and sale only profit/ income on sales could\nbe assessed as undisclosed income and could be subjected to tax. Case laws to\nthe point are as under: 1. Dr. T.A. Quereshi (157 taxmann.com 514) (Supreme\nCourt) 2. Piara Singh (124 ITR 40) (Supreme Court) 3. S.C. Kothari (82 ITR\n794 (Supreme Court) 23.5 The assessee admitted such profit at Rs.45,00,000/-\nand disclosed that on said transactions income in PMGKY, 2016 and paid due\ntax thereon. The copy of certificate issued by PCIT is placed on record. Thus\nwhen that transactions are of unrecorded purchase and sale of gold, which…

SIX TWENTY REALTY PVT. LTD.,RAJKOT vs. DCIT, CC-1, RAJKOT, RAJKOT

ITA 785/RJT/2024[2018-19]Status: DisposedITAT Rajkot11 Mar 2026AY 2018-19

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinha

For Appellant: Shri Mehul Ranpura, Ld.ARFor Respondent: Shri Sanjay Punglia, Ld. CIT(DR)
Section 133ASection 143(3)Section 147Section 148Section 250

…he unaccounted transaction of purchase and sale only profit/ income on sales could be assessed as undisclosed income and could be subjected to tax. Case laws to the point are as under: 1. Dr. T.A. Quereshi (157 taxmann.com 514) (Supreme Court) 2. Piara Singh (124 ITR 40) (Supreme Court) 3. S.C. Kothari (82 ITR 794 (Supreme Court) 23.5 The assessee admitted such profit at Rs. 45,00,000/- and disclosed that on said transactions income in PMGKY, 2016 and paid due tax thereon. The copy of certificate issued by PCIT is placed on record. Thus when that transactions are of unrecorded purchase and sale of gold, which Ld.…

DCIT, CENTRAL CIRCLE-1, RAJKOT, RAJKOT vs. SIX TWENTY REALTY PRIVATE LIMITED, RAJKOT

ITA 765/RJT/2024[2019-20]Status: DisposedITAT Rajkot11 Mar 2026AY 2019-20
Section 133ASection 143(3)Section 147Section 148Section 250

…unaccounted transaction of purchase and sale only profit/ income on sales could\nbe assessed as undisclosed income and could be subjected to tax. Case laws to\nthe point are as under: 1. Dr. T.A. Quereshi (157 taxmann.com 514) (Supreme\nCourt) 2. Piara Singh (124 ITR 40) (Supreme Court) 3. S.C. Kothari (82 ITR\n794 (Supreme Court) 23.5 The assessee admitted such profit at Rs.45,00,000/-\nand disclosed that on said transactions income in PMGKY, 2016 and paid due\ntax thereon. The copy of certificate issued by PCIT is placed on record. Thus\nwhen that transactions are of unrecorded purchase and sale of gold, which…

DCIT, CENTRAL CIRCLE 1, RAJKOT, RAJKOT vs. BUILDFOLIO REALTIES LLP, RAJKOT

ITA 683/RJT/2024[2021-22]Status: DisposedITAT Rajkot11 Mar 2026AY 2021-22
Section 132Section 143(3)Section 147

…unaccounted transaction of purchase and sale only profit/ income on sales could\nbe assessed as undisclosed income and could be subjected to tax. Case laws to\nthe point are as under: 1. Dr. T.A. Quereshi (157 taxmann.com 514) (Supreme\nCourt) 2. Piara Singh (124 ITR 40) (Supreme Court) 3. S.C. Kothari (82 ITR\n794 (Supreme Court) 23.5 The assessee admitted such profit at Rs.45,00,000/-\nand disclosed that on said transactions income in PMGKY, 2016 and paid due\ntax thereon. The copy of certificate issued by PCIT is placed on record. Thus\nwhen that transactions are of unrecorded purchase and sale of gold, which…

DCIT, CENTRAL CIRCLE 1, RAJKOT, RAJKOT vs. R K DREAMLAND, RAJKOT

ITA 564/RJT/2024[2017-18]Status: DisposedITAT Rajkot11 Mar 2026AY 2017-18
For Appellant: Shri Mehul Ranpura, Ld.ARFor Respondent: Shri Sanjay Punglia, Ld. CIT(DR)
Section 143(3)Section 147Section 148Section 250

…unaccounted transaction of purchase and sale only profit/ income on sales could\nbe assessed as undisclosed income and could be subjected to tax. Case laws to\nthe point are as under: 1. Dr. T.A. Quereshi (157 taxmann.com 514) (Supreme\nCourt) 2. Piara Singh (124 ITR 40) (Supreme Court) 3. S.C. Kothari (82 ITR\n794 (Supreme Court) 23.5 The assessee admitted such profit at Rs.45,00,000/-\nand disclosed that on said transactions income in PMGKY, 2016 and paid due\ntax thereon. The copy of certificate issued by PCIT is placed on record. Thus\nwhen that transactions are of unrecorded purchase and sale of gold, which…

DCIT, CENTRAL CIRCLE 1, RAJKOT, RAJKOT vs. R K DREAMLAND, RAJKOT

ITA 563/RJT/2024[2016-17]Status: DisposedITAT Rajkot11 Mar 2026AY 2016-17
Section 143(3)Section 147Section 148Section 250

…unaccounted transaction of purchase and sale only profit/ income on sales could\nbe assessed as undisclosed income and could be subjected to tax. Case laws to\nthe point are as under: 1. Dr. T.A. Quereshi (157 taxmann.com 514) (Supreme\nCourt) 2. Piara Singh (124 ITR 40) (Supreme Court) 3. S.C. Kothari (82 ITR\n794 (Supreme Court) 23.5 The assessee admitted such profit at Rs.45,00,000/-\nand disclosed that on said transactions income in PMGKY, 2016 and paid due\ntax thereon. The copy of certificate issued by PCIT is placed on record. Thus\nwhen that transactions are of unrecorded purchase and sale of gold, which…

R K DREAMLAND,RAJKOT vs. DCIT, CC-1, RAJKOT, RAJKOT

ITA 560/RJT/2024[2021-22]Status: DisposedITAT Rajkot11 Mar 2026AY 2021-22
For Appellant: Shri Mehul Ranpura, Ld.ARFor Respondent: Shri Sanjay Punglia, Ld. CIT(DR)
Section 143(3)Section 147Section 148Section 250

…unaccounted transaction of purchase and sale only profit/ income on sales could\nbe assessed as undisclosed income and could be subjected to tax. Case laws to\nthe point are as under: 1. Dr. T.A. Quereshi (157 taxmann.com 514) (Supreme\nCourt) 2. Piara Singh (124 ITR 40) (Supreme Court) 3. S.C. Kothari (82 ITR\n794 (Supreme Court) 23.5 The assessee admitted such profit at Rs.45,00,000/-\nand disclosed that on said transactions income in PMGKY, 2016 and paid due\ntax thereon. The copy of certificate issued by PCIT is placed on record. Thus\nwhen that transactions are of unrecorded purchase and sale of gold, which…

R K DREAMLAND,RAJKOT vs. DCIT, CC-1, RAJKOT, RAJKOT

ITA 559/RJT/2024[2020-21]Status: DisposedITAT Rajkot11 Mar 2026AY 2020-21
Section 143(3)Section 147Section 148Section 250

…he unaccounted transaction of purchase and sale only profit/ income on sales could be assessed as undisclosed income and could be subjected to tax. Case laws to the point are as under: 1. Dr. T.A. Quereshi (157 taxmann.com 514) (Supreme Court) 2. Piara Singh (124 ITR 40) (Supreme Court) 3. S.C. Kothari (82 ITR 794 (Supreme Court) 23.5 The assessee admitted such profit at Rs.45,00,000/- and disclosed that on said transactions income in PMGKY, 2016 and paid due tax thereon. The copy of certificate issued by PCIT is placed on record. Thus when that transactions are of unrecorded purchase and sale of gold, which Ld.…

R K DREAMLAND,RAJKOT vs. DCIT, CC-1, RAJKOT, RAJKOT

ITA 558/RJT/2024[2019-20]Status: DisposedITAT Rajkot11 Mar 2026AY 2019-20
For Appellant: Shri Mehul Ranpura, Ld.ARFor Respondent: Shri Sanjay Punglia, Ld. CIT(DR)
Section 143(3)Section 147Section 148Section 250

…he unaccounted transaction of purchase and sale only profit/ income on sales could be assessed as undisclosed income and could be subjected to tax. Case laws to the point are as under: 1. Dr. T.A. Quereshi (157 taxmann.com 514) (Supreme Court) 2. Piara Singh (124 ITR 40) (Supreme Court) 3. S.C. Kothari (82 ITR 794 (Supreme Court) 23.5 The assessee admitted such profit at Rs.45,00,000/- and disclosed that on said transactions income in PMGKY, 2016 and paid due tax thereon. The copy of certificate issued by PCIT is placed on record. Thus when that transactions are of unrecorded purchase and sale of gold, which Ld.…

R K DREAMLAND,RAJKOT vs. DCIT, CC-1, RAJKOT, RAJKOT

ITA 557/RJT/2024[2018-19]Status: DisposedITAT Rajkot11 Mar 2026AY 2018-19
For Appellant: Shri Mehul Ranpura, Ld.ARFor Respondent: Shri Sanjay Punglia, Ld. CIT(DR)
Section 143(3)Section 147Section 148Section 250

…he unaccounted transaction of purchase and sale only profit/ income on sales could be assessed as undisclosed income and could be subjected to tax. Case laws to the point are as under: 1. Dr. T.A. Quereshi (157 taxmann.com 514) (Supreme Court) 2. Piara Singh (124 ITR 40) (Supreme Court) 3. S.C. Kothari (82 ITR 794 (Supreme Court) 23.5 The assessee admitted such profit at Rs.45,00,000/- and disclosed that on said transactions income in PMGKY, 2016 and paid due tax thereon. The copy of certificate issued by PCIT is placed on record. Thus when that transactions are of unrecorded purchase and sale of gold, which Ld.…

RK DREAMLAND,RAJKOT vs. ACIT, CC-1, RAJKOT, RAJKOT

ITA 556/RJT/2024[2017-18]Status: DisposedITAT Rajkot11 Mar 2026AY 2017-18
Section 143(3)Section 147Section 148Section 250

…unaccounted transaction of purchase and sale only profit/ income on sales could\nbe assessed as undisclosed income and could be subjected to tax. Case laws to\nthe point are as under: 1. Dr. T.A. Quereshi (157 taxmann.com 514) (Supreme\nCourt) 2. Piara Singh (124 ITR 40) (Supreme Court) 3. S.C. Kothari (82 ITR\n794 (Supreme Court) 23.5 The assessee admitted such profit at Rs.45,00,000/-\nand disclosed that on said transactions income in PMGKY, 2016 and paid due\ntax thereon. The copy of certificate issued by PCIT is placed on record. Thus\nwhen that transactions are of unrecorded purchase and sale of gold, which…

R K DREAMLAND,RAJKOT vs. ACIT, CC-1, RAJKOT, RAJOKT

ITA 555/RJT/2024[2016-17]Status: DisposedITAT Rajkot11 Mar 2026AY 2016-17
Section 143(3)Section 147Section 148Section 250

…unaccounted transaction of purchase and sale only profit/ income on sales could\nbe assessed as undisclosed income and could be subjected to tax. Case laws to\nthe point are as under: 1. Dr. T.A. Quereshi (157 taxmann.com 514) (Supreme\nCourt) 2. Piara Singh (124 ITR 40) (Supreme Court) 3. S.C. Kothari (82 ITR\n794 (Supreme Court) 23.5 The assessee admitted such profit at Rs.45,00,000/-\nand disclosed that on said transactions income in PMGKY, 2016 and paid due\ntax thereon. The copy of certificate issued by PCIT is placed on record. Thus\nwhen that transactions are of unrecorded purchase and sale of gold, which…

BUILDFOLIO REALITIES LLP,RAJKOT vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL -1,, RAJKOT

ITA 510/RJT/2024[2022-23]Status: DisposedITAT Rajkot11 Mar 2026AY 2022-23

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं/.Ita No. 509 & 510/Rjt/2024 "नधा"रणवष"/ Assessment Year: 2021-22 & 2022-23 (Hybrid Hearing) Buildfolio Realities Llp The Deputy Commissioner Of Vs Income Tax, Central-1 . Shop No. 5Gf, Business Edifice, Canal Road 37, Income Tax Office, Amruta Karanpura Corner, Rajkot Estate Building, Near Girnar Cinema, M G Road, Rajkot Rajkot-360005 Rajkot-360001 "ायीलेखासं/.जीआइआरसं/.Pan/Gir No.: Aawfb8233C (अपीलाथ"/Appellant) (""थ"/Respondent)

For Appellant: Shri D.M. Rindani, Ld.ARFor Respondent: Shri Sanjay Punglia, Ld. CIT(DR)
Section 132Section 133ASection 143(3)Section 147

…he unaccounted transaction of purchase and sale only profit/ income on sales could be assessed as undisclosed income and could be subjected to tax. Case laws to the point are as under: 1. Dr. T.A. Quereshi (157 taxmann.com 514) (Supreme Court) 2. Piara Singh (124 ITR 40) (Supreme Court) 3. S.C. Kothari (82 ITR 794 (Supreme Court) 23.5 The assessee admitted such profit at Rs. 45,00,000/- and disclosed that on said transactions income in PMGKY, 2016 and paid due tax thereon. The copy of certificate issued by PCIT is placed on record. Thus when that transactions are of unrecorded purchase and sale of gold, which Ld.…

BUILDFOLIO REALITIES LLP,RAJKOT vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL -1, RAJKOT

ITA 509/RJT/2024[2021-22]Status: DisposedITAT Rajkot11 Mar 2026AY 2021-22

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं/.Ita No. 509 & 510/Rjt/2024 "नधा"रणवष"/ Assessment Year: 2021-22 & 2022-23 (Hybrid Hearing) Buildfolio Realities Llp The Deputy Commissioner Of Vs Income Tax, Central-1 . Shop No. 5Gf, Business Edifice, Canal Road 37, Income Tax Office, Amruta Karanpura Corner, Rajkot Estate Building, Near Girnar Cinema, M G Road, Rajkot Rajkot-360005 Rajkot-360001 "ायीलेखासं/.जीआइआरसं/.Pan/Gir No.: Aawfb8233C (अपीलाथ"/Appellant) (""थ"/Respondent)

For Appellant: Shri D.M. Rindani, Ld.ARFor Respondent: Shri Sanjay Punglia, Ld. CIT(DR)
Section 132Section 133ASection 143(3)Section 147

…he unaccounted transaction of purchase and sale only profit/ income on sales could be assessed as undisclosed income and could be subjected to tax. Case laws to the point are as under: 1. Dr. T.A. Quereshi (157 taxmann.com 514) (Supreme Court) 2. Piara Singh (124 ITR 40) (Supreme Court) 3. S.C. Kothari (82 ITR 794 (Supreme Court) 23.5 The assessee admitted such profit at Rs. 45,00,000/- and disclosed that on said transactions income in PMGKY, 2016 and paid due tax thereon. The copy of certificate issued by PCIT is placed on record. Thus when that transactions are of unrecorded purchase and sale of gold, which Ld.…

DCIT, CENTRAL CIRCLE 1, RAJKOT, RAJKOT vs. RADHE DEVELOPERS, RAJKOT

ITA 687/RJT/2024[2017-18]Status: DisposedITAT Rajkot10 Mar 2026AY 2017-18

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinhaआयकर अपील सं/.Ita No. 549 & 550/Rjt/2024 िनधा"रणवष"/ Assessment Year: 2017-18 & 2018-19 (Hybrid Hearing) Radhe Developers Vs The Deputy Commissioner Of Income Tax, Central-1 . Office No. 47, Ankur Commercial Center, Opp. Income Tax Office, Amruta Swaminarayan Gurukul, Estate Building, Near Girnar Gondal Road, Rajkot Cinema, M G Road, Rajkot Rajkot-360001 Rajkot-360001 "ायीलेखासं./जीआइआरसं./Pan/Gir No.: Aatfr3387E (अपीलाथ"/Appellant) (""थ"/Respondent)

For Appellant: Shri D.M. Rindani, Ld.ARFor Respondent: Shri Sanjay Punglia, Ld. CIT(DR)
Section 132Section 133ASection 143(3)Section 147

…he unaccounted transaction of purchase and sale only profit/ income on sales could be assessed as undisclosed income and could be subjected to tax. Case laws to the point are as under: 1. Dr. T.A. Quereshi (157 taxmann.com 514) (Supreme Court) 2. Piara Singh (124 ITR 40) (Supreme Court) 3. S.C. Kothari (82 ITR 794 (Supreme Court) 23.5 The assessee admitted such profit at Rs. 45,00,000/- and disclosed that on said transactions income in PMGKY, 2016 and paid due tax thereon. The copy of certificate issued by PCIT is placed on record. Thus when that transactions are of unrecorded purchase and sale of gold, which Ld.…

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CIT v. Piara Singh (124 ITR 40) — Cited in 95 Judgments | BharatTax