DCIT v. Panna Corporation

74 DTR 89High Court2012#1691 most cited

What is DCIT v. Panna Corporation authority for?

When unaccounted cash or on-money receipts are detected, only the profit element embedded in such receipts is taxable, not the entire gross amount, and this profit requires estimation.

67

judgments rely on this decision, according to BharatTax’s citation analysis of 366,314 Indian tax judgments — from 2019 to 2026.

Also referred to as

DCIT v. Panna Corporation · Panna Corporation · 74 DTR 89 · on-money receipt · unaccounted cash receipt · profit embedded · estimation of profit · section 145(3) · rejection of books · business income.

Sections most often in play

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

Issues it is cited on

on money receiptsection 145(2)project completion methodsection 256(1)section 199rejection of books of accountsection 256on-moneyspecified authorityicdssection 145(3)loose papers

Judgments citing DCIT v. Panna Corporation

Kewal Krishan, Chandigarh vs. Jao DCIT/ACIT JCIT (OSD)(Central Circle)-1, Chandigarh.

In the result, all the above appeals are partly allowed

ITA 1273/CHANDI/2025[2020-21]Status: DisposedITAT Chandigarh10 Mar 2026AY 2020-21
For Appellant: Shri Sudhir Sehgal, AdvocateFor Respondent: Shri Manav Bansal, CIT, DR
Section 144BSection 148Section 151A

…tten submissions relied upon the further following arguments:- "The finding of the CIT(A) is contradictory in the sense that the seized data had to be considered in totality and there is judgment of Gujarat High in the case of 'Panna Corporation' reported in 74 DTR 89 (Guj.) and in the case of Navjeevan Oil Mills, reported in 252 ITR 417, wherein, The Hon'ble Court has held that seized material cannot be dissected selectively, but must be considered in its entirety. The same view has been taken by the Hon'ble Supreme Court in the case of 'Bilhari Investment Pvt. Ltd.' 299 ITR 1, wherein, it has been held that, w…

Chandigarh Royale City Promoters Private Limited, Chandigarh vs. Jao DCIT/ACIT/JCIT(OSD) Central Circle-1, Chandigarh

In the result, all the above appeals are partly allowed

ITA 1272/CHANDI/2025[2023-2024]Status: DisposedITAT Chandigarh10 Mar 2026AY 2023-2024

Bench: SHRI. RAJPAL YADAV (Vice President), SHRI. KRINWANT SAHAY (Accountant Member)

For Appellant: Shri Sudhir Sehgal, AdvocateFor Respondent: Shri Manav Bansal, CIT, DR
Section 144BSection 148Section 151A

…tten submissions relied upon the further following arguments:- "The finding of the CIT(A) is contradictory in the sense that the seized data had to be considered in totality and there is judgment of Gujarat High in the case of 'Panna Corporation' reported in 74 DTR 89 (Guj.) and in the case of Navjeevan Oil Mills, reported in 252 ITR 417, wherein, The Hon'ble Court has held that seized material cannot be dissected selectively, but must be considered in its entirety. The same view has been taken by the Hon'ble Supreme Court in the case of 'Bilhari Investment Pvt. Ltd.' 299 ITR 1, wherein, it has been held that, w…

Chandigarh Royale City Promoters Private Limited, Chandigarh vs. Jao DCIT/ACIT/JCIT(OSD) Central Circle-1, Chandigarh

In the result, all the above appeals are partly allowed

ITA 1271/CHANDI/2025[2022-2023]Status: DisposedITAT Chandigarh10 Mar 2026AY 2022-2023
For Appellant: Shri Sudhir Sehgal, AdvocateFor Respondent: Shri Manav Bansal, CIT, DR
Section 144BSection 148Section 151A

…tten submissions relied upon the further following arguments:- "The finding of the CIT(A) is contradictory in the sense that the seized data had to be considered in totality and there is judgment of Gujarat High in the case of 'Panna Corporation' reported in 74 DTR 89 (Guj.) and in the case of Navjeevan Oil Mills, reported in 252 ITR 417, wherein, The Hon'ble Court has held that seized material cannot be dissected selectively, but must be considered in its entirety. The same view has been taken by the Hon'ble Supreme Court in the case of 'Bilhari Investment Pvt. Ltd.' 299 ITR 1, wherein, it has been held that, w…

Chandigarh Royale City Promoters Private Limited, Chandigarh vs. Jao DCIT/ACIT/JCIT (OSD) Central Circle-1, Chandigarh

In the result, all the above appeals are partly allowed

ITA 1270/CHANDI/2025[2021-2022]Status: DisposedITAT Chandigarh10 Mar 2026AY 2021-2022

Bench: SHRI. RAJPAL YADAV (Vice President), SHRI. KRINWANT SAHAY, AM आयकर अपील सं . / ITA No. 1269 To 1272/Chd/2025 निर्धारण वर्ष / Assessment Year : 2020-21 Το 2023-24 Chandigarh Royale City Promoters बनाम JAO DCIT/ACIT/JCIT (OSD) Central Private Limited, Circle-1, Chandigarh-160017 SCO-44, Sector-20C, Chandigarh स्थायी लेखा सं./ PAN NO: AAECC3999H अपीलार्थी/Appellant प्रत्यर्थी / Respondent आयकर अपील सं. / ITA No. 1273 Το 1275/Chd/ 2025 निर्धारण वर्ष / Assessment Year : 2020-21, 2021-22 & 2023-2

For Appellant: Shri Sudhir Sehgal, AdvocateFor Respondent: Shri Manav Bansal, CIT, DR
Section 144BSection 148Section 151A

…tten submissions relied upon the further following arguments:- "The finding of the CIT(A) is contradictory in the sense that the seized data had to be considered in totality and there is judgment of Gujarat High in the case of 'Panna Corporation' reported in 74 DTR 89 (Guj.) and in the case of Navjeevan Oil Mills, reported in 252 ITR 417, wherein, The Hon'ble Court has held that seized material cannot be dissected selectively, but must be considered in its entirety. The same view has been taken by the Hon'ble Supreme Court in the case of 'Bilhari Investment Pvt. Ltd.' 299 ITR 1, wherein, it has been held that, w…

Chandigarh Royale City Promoters Private Limited, Chandigarh vs. Jao DCIT/ACIT/JCIT(OSD) Central Circle-1, Chandigarh

In the result, all the above appeals are partly allowed

ITA 1269/CHANDI/2025[2020-2021]Status: DisposedITAT Chandigarh10 Mar 2026AY 2020-2021

Bench: SHRI. RAJPAL YADAV (Vice President), SHRI. KRINWANT SAHAY (Accountant Member)

For Appellant: Shri Sudhir Sehgal, AdvocateFor Respondent: Shri Manav Bansal, CIT, DR
Section 144BSection 148Section 151A

…tten submissions relied upon the further following arguments:- "The finding of the CIT(A) is contradictory in the sense that the seized data had to be considered in totality and there is judgment of Gujarat High in the case of 'Panna Corporation' reported in 74 DTR 89 (Guj.) and in the case of Navjeevan Oil Mills, reported in 252 ITR 417, wherein, The Hon'ble Court has held that seized material cannot be dissected selectively, but must be considered in its entirety. The same view has been taken by the Hon'ble Supreme Court in the case of 'Bilhari Investment Pvt. Ltd.' 299 ITR 1, wherein, it has been held that, w…

DCIT, Central Circle 1, Rajkot vs. Krishna Developers, Rajkot

ITA 688/RJT/2024[2018-19]Status: DisposedITAT Rajkot09 Mar 2026AY 2018-19

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

For Appellant: Shri D.M. Rindani, Ld. ARFor Respondent: Shri Sanjay Punglia, Ld. CIT(DR)
Section 132Section 133ASection 143(3)Section 147Section 250

…n'ble Gujarat High Court has held that only profit element embedded in the gross on-money receipts can be taxed. For this, the Hon'ble court has derived reference from its earlier decision delivered in the case of DCIT Vs. Panna Corporation reported in [2012] 74 DTR 89. Relevant part of the decision is as under - "it has been consistently held by this court and some other courts have been following the principle that even upon detection of on-money receipt or unaccounted cash receipt, what can be brought to tax is the profit embedded in such receipts and not the entire receipts themselves. If that were the legal…

Krishna Developers, Rajkot vs. Deputy Commissioner of Income Tax, Central 1, Rajkot

ITA 544/RJT/2024[2019-20]Status: DisposedITAT Rajkot09 Mar 2026AY 2019-20

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

For Appellant: Shri D.M. Rindani, Ld. ARFor Respondent: Shri Sanjay Punglia, Ld. CIT(DR)
Section 132Section 133ASection 143(3)Section 147Section 250

…n'ble Gujarat High Court has held that only profit element embedded in the gross on-money receipts can be taxed. For this, the Hon'ble court has derived reference from its earlier decision delivered in the case of DCIT Vs. Panna Corporation reported in [2012] 74 DTR 89. Relevant part of the decision is as under - "it has been consistently held by this court and some other courts have been following the principle that even upon detection of on-money receipt or unaccounted cash receipt, what can be brought to tax is the profit embedded in such receipts and not the entire receipts themselves. If that were the legal…

Krishna Developers, Rajkot vs. The Deputy Commissioner of Income Tax, Central-1, Rajkot

ITA 543/RJT/2024[2018-19]Status: DisposedITAT Rajkot09 Mar 2026AY 2018-19

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

For Appellant: Shri D.M. Rindani, Ld. ARFor Respondent: Shri Sanjay Punglia, Ld. CIT(DR)
Section 132Section 133ASection 143(3)Section 147Section 250

…n'ble Gujarat High Court has held that only profit element embedded in the gross on-money receipts can be taxed. For this, the Hon'ble court has derived reference from its earlier decision delivered in the case of DCIT Vs. Panna Corporation reported in [2012] 74 DTR 89. Relevant part of the decision is as under - "it has been consistently held by this court and some other courts have been following the principle that even upon detection of on-money receipt or unaccounted cash receipt, what can be brought to tax is the profit embedded in such receipts and not the entire receipts themselves. If that were the legal…

DCIT, Central Cirlcle 1, Rajkot vs. Buildcon Creations LLP, Rajkot

ITA 679/RJT/2024[2022-23]Status: DisposedITAT Rajkot27 Feb 2026AY 2022-23

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinhaआयकर अपील सं./Ita Nos. 539 To 542/Rjt/2024 (Assessment Year: 2019-20 To 2022-23) (Hybrid Hearing)

For Appellant: Shri D.M. Rindani / Ms. Devina Patel, Ld. ARFor Respondent: Shri Sanjay Punglia, CIT-DR
Section 143(3)Section 147

…eipts can be taxed. For this, the Hon'ble court has derived reference from its earlier decision delivered in the case of DCIT Vs. Panna I.T.A Nos. 539 to 542, 676 to 679/Rjt/2024 A.Y. 2019-20 to 2022-23 Buildcon Creations LLP Corporation reported in [2012] 74 DTR 89. Relevant part of the decision is as under - "it has been consistently held by this court and some other courts have been following the principle that even upon detection of on-money receipt or unaccounted cash receipt, what can be brought to tax is the profit embedded in such receipts and not the entire receipts themselves If that were the legal…

DCIT, Central Circle 1, Rajkot vs. Buildcon Creations LLP, Rajkot

ITA 678/RJT/2024[2021-22]Status: DisposedITAT Rajkot27 Feb 2026AY 2021-22

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinhaआयकर अपील सं./Ita Nos. 539 To 542/Rjt/2024 (Assessment Year: 2019-20 To 2022-23) (Hybrid Hearing)

For Appellant: Shri D.M. Rindani / Ms. Devina Patel, Ld. ARFor Respondent: Shri Sanjay Punglia, CIT-DR
Section 143(3)Section 147

…eipts can be taxed. For this, the Hon'ble court has derived reference from its earlier decision delivered in the case of DCIT Vs. Panna I.T.A Nos. 539 to 542, 676 to 679/Rjt/2024 A.Y. 2019-20 to 2022-23 Buildcon Creations LLP Corporation reported in [2012] 74 DTR 89. Relevant part of the decision is as under - "it has been consistently held by this court and some other courts have been following the principle that even upon detection of on-money receipt or unaccounted cash receipt, what can be brought to tax is the profit embedded in such receipts and not the entire receipts themselves If that were the legal…

DCIT, Central Circle-1, Rajkot vs. Buildcon Creations LLP, Rajkot

ITA 677/RJT/2024[2020-21]Status: DisposedITAT Rajkot27 Feb 2026AY 2020-21

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinhaआयकर अपील सं./Ita Nos. 539 To 542/Rjt/2024 (Assessment Year: 2019-20 To 2022-23) (Hybrid Hearing)

For Appellant: Shri D.M. Rindani / Ms. Devina Patel, Ld. ARFor Respondent: Shri Sanjay Punglia, CIT-DR
Section 143(3)Section 147

…eipts can be taxed. For this, the Hon'ble court has derived reference from its earlier decision delivered in the case of DCIT Vs. Panna I.T.A Nos. 539 to 542, 676 to 679/Rjt/2024 A.Y. 2019-20 to 2022-23 Buildcon Creations LLP Corporation reported in [2012] 74 DTR 89. Relevant part of the decision is as under - "it has been consistently held by this court and some other courts have been following the principle that even upon detection of on-money receipt or unaccounted cash receipt, what can be brought to tax is the profit embedded in such receipts and not the entire receipts themselves If that were the legal…

DCIT, Central Circle 1, Rajkot vs. Buildcon Creations LLP, Rajkot

ITA 676/RJT/2024[2019-20]Status: DisposedITAT Rajkot27 Feb 2026AY 2019-20

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinhaआयकर अपील सं./Ita Nos. 539 To 542/Rjt/2024 (Assessment Year: 2019-20 To 2022-23) (Hybrid Hearing)

For Appellant: Shri D.M. Rindani / Ms. Devina Patel, Ld. ARFor Respondent: Shri Sanjay Punglia, CIT-DR
Section 143(3)Section 147

…eipts can be taxed. For this, the Hon'ble court has derived reference from its earlier decision delivered in the case of DCIT Vs. Panna I.T.A Nos. 539 to 542, 676 to 679/Rjt/2024 A.Y. 2019-20 to 2022-23 Buildcon Creations LLP Corporation reported in [2012] 74 DTR 89. Relevant part of the decision is as under - "it has been consistently held by this court and some other courts have been following the principle that even upon detection of on-money receipt or unaccounted cash receipt, what can be brought to tax is the profit embedded in such receipts and not the entire receipts themselves If that were the legal…

Shiv Enterprise, Rajkot vs. The Deuty Commissioner of Income Tax, Central - 1, Rajkot

ITA 616/RJT/2024[2020-21]Status: DisposedITAT Rajkot27 Feb 2026AY 2020-21

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

For Appellant: Shri D.M. Rindani & Ms. Devina Patel Ld. ARsFor Respondent: Shri Abhimanyu Singh Yadav, Ld. SR. DR
Section 132Section 133ASection 143(3)Section 147

…money receipts can be taxed. For this, the Hon'ble court has derived reference from its earlier decision delivered in the case ITA Nos. 613 to 616/Rjt/2024 – A.Ys. 2017-18 to 2020-21 (Shiv Enterprise vs. DCIT) of DCIT Vs. Panna Corporation reported in [2012] 74 DTR 89. Relevant part of the decision is as under - "It has been consistently held by this court and some other courts have been following the principle that even upon detection of on-money receipt or unaccounted cash receipt, what can be brought to tax is the profit embedded in such receipts and not the entire receipts themselves. If that were the legal…

Shiv Enterprise, Rajkot vs. The Deputy Commissioner of Income Tax, Central-1, Rajkot

ITA 615/RJT/2024[2019-20]Status: DisposedITAT Rajkot27 Feb 2026AY 2019-20

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

For Appellant: Shri D.M. Rindani & Ms. Devina Patel Ld. ARsFor Respondent: Shri Abhimanyu Singh Yadav, Ld. SR. DR
Section 132Section 133ASection 143(3)Section 147

…money receipts can be taxed. For this, the Hon'ble court has derived reference from its earlier decision delivered in the case ITA Nos. 613 to 616/Rjt/2024 – A.Ys. 2017-18 to 2020-21 (Shiv Enterprise vs. DCIT) of DCIT Vs. Panna Corporation reported in [2012] 74 DTR 89. Relevant part of the decision is as under - "It has been consistently held by this court and some other courts have been following the principle that even upon detection of on-money receipt or unaccounted cash receipt, what can be brought to tax is the profit embedded in such receipts and not the entire receipts themselves. If that were the legal…

Shiv Enterprise, Rajkot vs. The Deputy Commissioner of Income Tax, Central -1, Rajkot

ITA 614/RJT/2024[2018-19]Status: DisposedITAT Rajkot27 Feb 2026AY 2018-19

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

For Appellant: Shri D.M. Rindani & Ms. Devina Patel Ld. ARsFor Respondent: Shri Abhimanyu Singh Yadav, Ld. SR. DR
Section 132Section 133ASection 143(3)Section 147

…money receipts can be taxed. For this, the Hon'ble court has derived reference from its earlier decision delivered in the case ITA Nos. 613 to 616/Rjt/2024 – A.Ys. 2017-18 to 2020-21 (Shiv Enterprise vs. DCIT) of DCIT Vs. Panna Corporation reported in [2012] 74 DTR 89. Relevant part of the decision is as under - "It has been consistently held by this court and some other courts have been following the principle that even upon detection of on-money receipt or unaccounted cash receipt, what can be brought to tax is the profit embedded in such receipts and not the entire receipts themselves. If that were the legal…

Shiv Enterprise, Rajkot vs. The Deputy Commissioner of Income Tax, Central 1, Rajkot

ITA 613/RJT/2024[2017-18]Status: DisposedITAT Rajkot27 Feb 2026AY 2017-18

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

For Appellant: Shri D.M. Rindani & Ms. Devina Patel Ld. ARsFor Respondent: Shri Abhimanyu Singh Yadav, Ld. SR. DR
Section 132Section 133ASection 143(3)Section 147

…money receipts can be taxed. For this, the Hon'ble court has derived reference from its earlier decision delivered in the case ITA Nos. 613 to 616/Rjt/2024 – A.Ys. 2017-18 to 2020-21 (Shiv Enterprise vs. DCIT) of DCIT Vs. Panna Corporation reported in [2012] 74 DTR 89. Relevant part of the decision is as under - "It has been consistently held by this court and some other courts have been following the principle that even upon detection of on-money receipt or unaccounted cash receipt, what can be brought to tax is the profit embedded in such receipts and not the entire receipts themselves. If that were the legal…

Buildcon Creations LLP, Rajkot vs. The Deputy Commissioner of Income Tax, Central-1, Rajkot

ITA 542/RJT/2024[2022-23]Status: DisposedITAT Rajkot27 Feb 2026AY 2022-23

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinhaआयकर अपील सं./Ita Nos. 539 To 542/Rjt/2024 (Assessment Year: 2019-20 To 2022-23) (Hybrid Hearing)

For Appellant: Shri D.M. Rindani / Ms. Devina Patel, Ld. ARFor Respondent: Shri Sanjay Punglia, CIT-DR
Section 143(3)Section 147

…eipts can be taxed. For this, the Hon'ble court has derived reference from its earlier decision delivered in the case of DCIT Vs. Panna I.T.A Nos. 539 to 542, 676 to 679/Rjt/2024 A.Y. 2019-20 to 2022-23 Buildcon Creations LLP Corporation reported in [2012] 74 DTR 89. Relevant part of the decision is as under - "it has been consistently held by this court and some other courts have been following the principle that even upon detection of on-money receipt or unaccounted cash receipt, what can be brought to tax is the profit embedded in such receipts and not the entire receipts themselves If that were the legal…

Buildcon Creations LLP, Rajkot vs. The Deputy Commissioner of Income Tax, Central -1, Rajkot

ITA 541/RJT/2024[2021-22]Status: DisposedITAT Rajkot27 Feb 2026AY 2021-22

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinhaआयकर अपील सं./Ita Nos. 539 To 542/Rjt/2024 (Assessment Year: 2019-20 To 2022-23) (Hybrid Hearing)

For Appellant: Shri D.M. Rindani / Ms. Devina Patel, Ld. ARFor Respondent: Shri Sanjay Punglia, CIT-DR
Section 143(3)Section 147

…eipts can be taxed. For this, the Hon'ble court has derived reference from its earlier decision delivered in the case of DCIT Vs. Panna I.T.A Nos. 539 to 542, 676 to 679/Rjt/2024 A.Y. 2019-20 to 2022-23 Buildcon Creations LLP Corporation reported in [2012] 74 DTR 89. Relevant part of the decision is as under - "it has been consistently held by this court and some other courts have been following the principle that even upon detection of on-money receipt or unaccounted cash receipt, what can be brought to tax is the profit embedded in such receipts and not the entire receipts themselves If that were the legal…

Buildcon Creations LLP, Rajkot vs. The Deputy Commissioner of Income Tax, Central -1, Rajkot

ITA 540/RJT/2024[2020-21]Status: DisposedITAT Rajkot27 Feb 2026AY 2020-21

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinhaआयकर अपील सं./Ita Nos. 539 To 542/Rjt/2024 (Assessment Year: 2019-20 To 2022-23) (Hybrid Hearing)

For Appellant: Shri D.M. Rindani / Ms. Devina Patel, Ld. ARFor Respondent: Shri Sanjay Punglia, CIT-DR
Section 143(3)Section 147

…eipts can be taxed. For this, the Hon'ble court has derived reference from its earlier decision delivered in the case of DCIT Vs. Panna I.T.A Nos. 539 to 542, 676 to 679/Rjt/2024 A.Y. 2019-20 to 2022-23 Buildcon Creations LLP Corporation reported in [2012] 74 DTR 89. Relevant part of the decision is as under - "it has been consistently held by this court and some other courts have been following the principle that even upon detection of on-money receipt or unaccounted cash receipt, what can be brought to tax is the profit embedded in such receipts and not the entire receipts themselves If that were the legal…

Buildcon Creations LLP, Rajkot vs. The Deputy Commissioner of Income Tax, Central -1, Rajkot

ITA 539/RJT/2024[2019-20]Status: DisposedITAT Rajkot27 Feb 2026AY 2019-20

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinhaआयकर अपील सं./Ita Nos. 539 To 542/Rjt/2024 (Assessment Year: 2019-20 To 2022-23) (Hybrid Hearing)

For Appellant: Shri D.M. Rindani / Ms. Devina Patel, Ld. ARFor Respondent: Shri Sanjay Punglia, CIT-DR
Section 143(3)Section 147

…eipts can be taxed. For this, the Hon'ble court has derived reference from its earlier decision delivered in the case of DCIT Vs. Panna I.T.A Nos. 539 to 542, 676 to 679/Rjt/2024 A.Y. 2019-20 to 2022-23 Buildcon Creations LLP Corporation reported in [2012] 74 DTR 89. Relevant part of the decision is as under - "it has been consistently held by this court and some other courts have been following the principle that even upon detection of on-money receipt or unaccounted cash receipt, what can be brought to tax is the profit embedded in such receipts and not the entire receipts themselves If that were the legal…