(vi) Daulatram Rawatmull v. CIT

48 ITR 254High Court1963#4367 most cited

What is (vi) Daulatram Rawatmull v. CIT authority for?

An unexplained cash credit found in the business accounts of an assessee, where the explanation for its origin is rejected and it's treated as income from an undisclosed source, can be considered business income if the assessee has no other source of income.

27

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2020 to 2026.

Also referred to as

Daulatram Rawatmull v. CIT · 48 ITR 254 · unexplained cash credit · undisclosed source · business income · no other source of income · income from undisclosed source

Sections most often in play

Section 115BBESection 143(3)Section 69BSection 153ASection 132(4)Section 68Section 69CSection 28

Issues it is cited on

abatement of assessmentsection 4(1)section 153a proceedingssection 69dwarrant of authorisationsection 71third party informationsection 158bdsection 60surrender of incomesection 69bset off of losses

Judgments citing (vi) Daulatram Rawatmull v. CIT

DCIT, DELHI vs. JMK JEWELS PRIVATE LIMITED, DELHI

ITA 4282/DEL/2025[2017-18]Status: DisposedITAT Delhi07 Jan 2026AY 2017-18

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwalassessment Year: 2017-18 M/S. Jmk Jewels Pvt. Ltd., Vs. Acit, Shop No. 302, Building New Delhi No.2678/1, Diamond Mall, Main Gurudwara Road, Karol Bagh, New Delhi Pan: Aabch6018F (Appellant) (Respondent) With Assessment Year: 2017-18 Dcit, Vs. M/S. Jmk Jewels Pvt. Ltd., New Delhi Shop No. 302, Building No.2678/1, Diamond Mall, Main Gurudwara Road, Karol Bagh, New Delhi Pan: Aabch6018F (Appellant) (Respondent) Assessee By Sh. Pranshu Singhal, Ca Sh. Rahul Bhardwaj, Adv. Department By Sh. Mahesh Kumar, Cit(Dr), Sh. Rajesh Tiwari, Sr. Dr

Section 115BSection 143(3)Section 44ASection 68

…IN THE INCOME TAX APPELLATE TRIBUNAL, DELHI BENCH: ‘G’ NEW DELHI BEFORE SHRI SATBEER SINGH GODARA, JUDICIAL MEMBER AND SHRI MANISH AGARWAL, ACCOUNTANT MEMBER Assessment Year: 2017-18 M/s. JMK Jewels Pvt. Ltd., Vs. ACIT, Shop No. 302, Building New Delhi No.2678/1, Diamond Mall, Main Gurudwara Road, Karol Bagh, New Delhi PAN: AABCH6018F (Appellant) (Respondent) With Assessment Year: 2017-18 DCIT, Vs. M/s. JMK Jewels Pvt. Ltd., New Delhi Shop No. 302, Building No.2678/1, Diamond Mall, Main Gurudwara Road, Karol Bagh, New Delhi PAN: AABCH6018F (Appellant) (Respondent) Assessee by Sh. Pranshu Singhal, CA Sh. Rahul Bha…

JMK JEWELS PRIVATE LIMITED,DELHI vs. ASSISTANT COMMISSIONER OF INCOME TAX, DELHI

ITA 3609/DEL/2025[2017-18]Status: DisposedITAT Delhi07 Jan 2026AY 2017-18

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwalassessment Year: 2017-18 M/S. Jmk Jewels Pvt. Ltd., Vs. Acit, Shop No. 302, Building New Delhi No.2678/1, Diamond Mall, Main Gurudwara Road, Karol Bagh, New Delhi Pan: Aabch6018F (Appellant) (Respondent) With Assessment Year: 2017-18 Dcit, Vs. M/S. Jmk Jewels Pvt. Ltd., New Delhi Shop No. 302, Building No.2678/1, Diamond Mall, Main Gurudwara Road, Karol Bagh, New Delhi Pan: Aabch6018F (Appellant) (Respondent) Assessee By Sh. Pranshu Singhal, Ca Sh. Rahul Bhardwaj, Adv. Department By Sh. Mahesh Kumar, Cit(Dr), Sh. Rajesh Tiwari, Sr. Dr

Section 115BSection 143(3)Section 44ASection 68

…IN THE INCOME TAX APPELLATE TRIBUNAL, DELHI BENCH: ‘G’ NEW DELHI BEFORE SHRI SATBEER SINGH GODARA, JUDICIAL MEMBER AND SHRI MANISH AGARWAL, ACCOUNTANT MEMBER Assessment Year: 2017-18 M/s. JMK Jewels Pvt. Ltd., Vs. ACIT, Shop No. 302, Building New Delhi No.2678/1, Diamond Mall, Main Gurudwara Road, Karol Bagh, New Delhi PAN: AABCH6018F (Appellant) (Respondent) With Assessment Year: 2017-18 DCIT, Vs. M/s. JMK Jewels Pvt. Ltd., New Delhi Shop No. 302, Building No.2678/1, Diamond Mall, Main Gurudwara Road, Karol Bagh, New Delhi PAN: AABCH6018F (Appellant) (Respondent) Assessee by Sh. Pranshu Singhal, CA Sh. Rahul Bha…

JAYVADAN RUGHNATHWALA,SURAT vs. ITO, WARD-1(2)(1), SURAT

ITA 923/SRT/2024[2018-19]Status: DisposedITAT Surat29 Aug 2025AY 2018-19

Bench: Ms. Suchitra Kamble & Shri Bijayananda Pruseth Assessment Year 2018-19

For Appellant: Shri Rasesh Shah, A.RFor Respondent: Shri Ajay Uke, Sr.D.R
Section 115BSection 147Section 148Section 148ASection 69C

…T v/s Radhe Developers India Ltd329 ITR 1 (Guj.) ix CIT vs Mhaskar General Hospital in Tax Appeal No 1474 of 2009 (Gu)) x Daulatram Rawatmull v CIT 64 ITR 593 (Cal) 7 I.T.A No. 923/Srt/2024 Jayvadan Rughnathwala, A.Y. 2018-19 xi. Mansfield and Sons v. CIT 48 ITR 254 (Cal.) xii. CIT v Chensing Ventures [(2007) 291 ITR 258 (Mad)] xii CIT v S K Srigir & Bros 171 Taxman 264 (Kar)” At the time of hearing, the ld. A.R. submitted that ground nos. 1 & 2 are not pressed. The ld. A.R. further submitted that the Hon’ble Gujarat High Court in case of Vardhaman Exports (265/2008) has categorically held that the payment w…

UMESH SABOO,JAIPUR vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-2,, JAIPUR

ITA 1271/JPR/2024[2017-18]Status: DisposedITAT Jaipur20 Aug 2025AY 2017-18
For Appellant: Shri S. L. Poddar, AdvFor Respondent: Mrs. Alka Gautam, CIT-DR
Section 115BSection 127Section 132Section 133ASection 139(1)Section 142(1)Section 143(3)Section 153ASection 271ASection 68

…rd that the appellant firm is doing\nsome other activities from which such income was earned and the\nexcess stock, excess cash found and the expenditure on renovation\nof shop represented the income from such other source.”\n(7)Mansfield & Sons Vs.CIT (1963) 48 ITR 254 (Hon'ble Calcutta\nHigh Court)\nWhere a credit entry is found in the business accounts of an\nassessee and the explanation as to how the amount came to be\nreceived is rejected by the IT authorities and the amount is taken to\nbe income from an undisclosed source, such income can be\ntreated as business income if the assessee has no other source o…

UMESH SABOO,JAIPUR vs. DEPUTY COMMISSIONER OF INCOME TAX-CENTRAL CIRCLE-2, JAIPUR

In the result, both the appeal filed by the assessee are partly\nallowed

ITA 1270/JPR/2024[2016-17]Status: DisposedITAT Jaipur20 Aug 2025AY 2016-17
For Appellant: Shri S. L. Poddar, AdvFor Respondent: Mrs. Alka Gautam, CIT-DR
Section 115BSection 127Section 132Section 133ASection 139(1)Section 142(1)Section 143(3)Section 153ASection 271ASection 68

…rd that the appellant firm is doing\nsome other activities from which such income was earned and the\nexcess stock, excess cash found and the expenditure on renovation\nof shop represented the income from such other source.”\n(7)Mansfield & Sons Vs.CIT (1963) 48 ITR 254 (Hon'ble Calcutta\nHigh Court)\nWhere a credit entry is found in the business accounts of an\nassessee and the explanation as to how the amount came to be\nreceived is rejected by the IT authorities and the amount is taken to\nbe income from an undisclosed source, such income can be\ntreated as business income if the assessee has no other source o…

ITO, WARD-24(1), NEW DELHI vs. SUN-NEW CREATIONS AND MARKETIGN PVT. LTD., NEW DELHI

The appeal of the revenue is dismissed

ITA 1096/DEL/2021[2017-18]Status: DisposedITAT Delhi25 Jun 2025AY 2017-18

Bench: Ms. Madhumita Roy & Shri Khettra Mohan Royito, Ward 24(1) Vs. M/S Sun New Creations New Delhi & Marketing Pvt. Ltd. A-2/71, Rajouri Garden, West Delhi, New Delhi – 110027 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aacch4883P Appellant .. Respondent C.O. No. 59/Del/2025 (Assessment Year 2017-18) M/S Sun New Creations Vs. Ito, Ward 24(1) & Marketing Pvt. Ltd. New Delhi A-2/71, Rajouri Garden, West Delhi, New Delhi – 110027 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aacch4883P Appellant .. Respondent

For Appellant: Sh. Vikas Jain, Adv, &For Respondent: Ms. Harpreet Kaur Hansra, Sr
Section 143(2)Section 143(3)Section 68

…e other than what has been declared by the appellant company in its books of accounts etc. and in fact the AO has accepted this position. 11.8 I have carefully pursued the views of Hon'ble Calcutta High Court in the case of: (i) Mansfield & Sons v. CIT(1963] 48 ITR 254 (Cal), wherein, it was held that where an unexplained cash credit is found in the business accounts of an assessee, such amount is taken to he income from an undisclosed source and the same can be treated as business income if the assessee has no other source of income, and taken into account as business income for purposes of excess profits tax.…

BHAGWATI PRASAD KHANDELWAL ,KOTA vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, KOTA, KOTA

In the result, ground No. 1 of the assessee is allowed

ITA 1494/JPR/2024[2018-19]Status: DisposedITAT Jaipur22 Apr 2025AY 2018-19

Bench: The Learned Ao & Treating The Same As Income From Other Sources. 2. The Assessee Craves Your Indulgence To Add, Amend Or Alter All Or Any Grounds Of Appeal Before Or At The Time Of Hearing.”

For Appellant: Shri Harsh Poddar, AdvocateFor Respondent: Mrs. Swapnil Parihar, JCIT-DR
Section 115BSection 133ASection 142(1)Section 143(2)Section 250Section 69

…cord that the appellant firm is doing some other activities from which such income was earned and the excess stock, excess cash found and the expenditure on renovation of shop represented the income from such other source.” (8) Mansfield & Sons Vs. CIT (1963) 48 ITR 254 (Hon’ble Calcutta High Court) Where a credit entry is found in the business accounts of an assessee and the explanation as to how the amount came to be received is rejected by IT authorities and the amount is taken to be income from an undisclosed source, such income can be treated as business income if the assessee has no other source of income.…

KEI INDUSTRIES LTD.,NEW DELHI vs. DCIT, CIRCLE-13(1), DELHI

The appeal of the revenue is dismissed

ITA 1096/DEL/2023[2018-19]Status: DisposedITAT Delhi28 Mar 2025AY 2018-19

Bench: Ms. Madhumita Roy & Shri Khettra Mohan Royito, Ward 24(1) Vs. M/S Sun New Creations New Delhi & Marketing Pvt. Ltd. A-2/71, Rajouri Garden, West Delhi, New Delhi – 110027 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aacch4883P Appellant .. Respondent C.O. No. 59/Del/2025 (Assessment Year 2017-18) M/S Sun New Creations Vs. Ito, Ward 24(1) & Marketing Pvt. Ltd. New Delhi A-2/71, Rajouri Garden, West Delhi, New Delhi – 110027 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aacch4883P Appellant .. Respondent

For Appellant: Sh. Vikas Jain, Adv, &For Respondent: Ms. Harpreet Kaur Hansra, Sr
Section 143(2)Section 143(3)Section 68

…e other than what has been declared by the appellant company in its books of accounts etc. and in fact the AO has accepted this position. 11.8 I have carefully pursued the views of Hon'ble Calcutta High Court in the case of: (i) Mansfield & Sons v. CIT(1963] 48 ITR 254 (Cal), wherein, it was held that where an unexplained cash credit is found in the business accounts of an assessee, such amount is taken to he income from an undisclosed source and the same can be treated as business income if the assessee has no other source of income, and taken into account as business income for purposes of excess profits tax.…

RIDHIRAJ BUILDERS,JAIPUR vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-6, NCRB, JAIPUR

In the result, the appeal of the assessee is allowed for statistical purposes

ITA 1167/JPR/2024[2015-16]Status: DisposedITAT Jaipur18 Mar 2025AY 2015-16

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Shri Surendra Sha, C.AFor Respondent: Shri Dinesh Badgujar, Addl.CIT a
Section 115BSection 127Section 142(1)Section 143(2)Section 143(3)Section 271(1)(c)Section 274Section 68

…income from an undisclosed source, such income can be treated as business income, if the assessee has no other source of income. 11 Ridhiraj Builders vs. DCIT  The same view has been taken by Calcutta High Court in case of Mansfield and Sons v. CIT [1963] 48 ITR 254. The surrender income disclosed by the assessee firm is part of the business activities and no other activities are carried out by the assessee firm and also no material or evidence brought on record by the Department and the provisions of section 68 applied by the Ld. AO and taxing the income under section 115 BBE is totally unjustifiable and als…

PREM LATA PANDYA,JAIPUR vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-4, , JAIPUR

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

ITA 1471/JPR/2024[2019-20]Status: DisposedITAT Jaipur27 Jan 2025AY 2019-20

Bench: SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member), SHRI NARINDER KUMAR, JM आयकर अपील सं. / ITA No. 1471/JPR/2024 निर्धारण वर्ष / Assessment Year :2019-20 Prem Lata Pandya बनाम Deputy Commissioner of 302, Raj Mension, D-299, Vs. Income Tax, Tulsi Marg Bani Park, Central Circle-4, Jaipur. Jaipur अपीलार्थी / Appellant प्रत्यर्थी / Respondent स्थायीलेखा सं./ जीआईआर सं./ PAN/GIR No.:ACXPJ9951A निधर्धारिती की ओरसे / Assessee by : Sh. S.L.Poddar, Adv. राजस्व की ओरसे / Revenue by: Sh. Gautam Singh

For Appellant: Sh. S.L.Poddar, AdvFor Respondent: Sh. Gautam Singh Choudhary, JCIT
Section 115BSection 127Section 132ASection 142(1)Section 143(2)Section 143(3)Section 69A

…s doing some other activities from which such income was earned and the excess stock, excess cash found and the expenditure on renovation of shop represented the income from such other source.” 13 Prem Lata Pandya vs. DCIT (7) Mansfield & Sons Vs.CIT (1963) 48 ITR 254 (Hon’ble Calcutta High Court) Where a credit entry is found in the business accounts of an assessee and the explanation as to how the amount came to be received is rejected by the IT authorities and the amount is taken to be income from an undisclosed source, such income can be treated as business income if the assessee has no other source of inco…

ASSISTANT COMMISSIONER OF INCOME TAX , CENTRAL CIRCLE, KOTA vs. BANAS BUILDERS AND DEVELOPERS LLP, JHALAWAR

In the result the appeal of the revenue in ITA no

ITA 269/JPR/2024[2018-19]Status: DisposedITAT Jaipur03 Dec 2024AY 2018-19

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Sh. Rajendra Jain (Adv.) (V.C)For Respondent: Smt. Alka Gautam, CIT-DR (V.H)
Section 153ASection 250Section 69B

…Court has observed that when an amount is credited in the business books, it is not an unreasonable inference to draw that it is a receipt from business. Similar views have been taken in Daulatram Rawatmull vs. CIT 64 ITR 593, Mansfield & Sons vs. CIT [1963] 48 ITR 254, besides others. It is submitted that the unexplained stock in trade is not covered by section 69B. Reference is also invited to Addl. CIT v. Danyabhai Pitamberdas & Co. [1974] Taxation 36(1) 25-26 (Guj.). 15. It is respectfully submitted that sans section 68 to section 69D, section 115BBE cannot be invoked. The assessee is in the business of Ko…

ASSTT. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, KOTA vs. BANAS MINERALS PRIVATE LIMITED, JHALAWAR

In the result the appeal of the revenue in ITA no

ITA 240/JPR/2024[2018-19]Status: DisposedITAT Jaipur03 Dec 2024AY 2018-19

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Sh. Rajendra Jain (Adv.) (V.C)For Respondent: Smt. Alka Gautam, CIT-DR (V.H)
Section 153ASection 250Section 69B

…Court has observed that when an amount is credited in the business books, it is not an unreasonable inference to draw that it is a receipt from business. Similar views have been taken in Daulatram Rawatmull vs. CIT 64 ITR 593, Mansfield & Sons vs. CIT [1963] 48 ITR 254, besides others. It is submitted that the unexplained stock in trade is not covered by section 69B. Reference is also invited to Addl. CIT v. Danyabhai Pitamberdas & Co. [1974] Taxation 36(1) 25-26 (Guj.). 15. It is respectfully submitted that sans section 68 to section 69D, section 115BBE cannot be invoked. The assessee is in the business of Ko…

ACIT, CENTRAL CIRCLE, KOTA vs. BANAS MINERALS PRIVATE LIMITED, JHALAWAR

In the result the appeal of the revenue in ITA no

ITA 239/JPR/2024[2013-14]Status: DisposedITAT Jaipur03 Dec 2024AY 2013-14

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Sh. Rajendra Jain (Adv.) (V.C)For Respondent: Smt. Alka Gautam, CIT-DR (V.H)
Section 153ASection 250Section 69B

…Court has observed that when an amount is credited in the business books, it is not an unreasonable inference to draw that it is a receipt from business. Similar views have been taken in Daulatram Rawatmull vs. CIT 64 ITR 593, Mansfield & Sons vs. CIT [1963] 48 ITR 254, besides others. It is submitted that the unexplained stock in trade is not covered by section 69B. Reference is also invited to Addl. CIT v. Danyabhai Pitamberdas & Co. [1974] Taxation 36(1) 25-26 (Guj.). 15. It is respectfully submitted that sans section 68 to section 69D, section 115BBE cannot be invoked. The assessee is in the business of Ko…

INCOME TAX OFFICER W 1, HASSAN vs. RAMACHANDRA SETTY AND SONS, HASSAN

In the result, appeal of the assessee in ITA

ITA 1166/BANG/2023[2017-18]Status: DisposedITAT Bangalore10 Jun 2024AY 2017-18

Bench: Shri Chandra Poojari & Shri Keshav Dubey

For Appellant: Shri C. Ramesh, A.RFor Respondent: Ms. Neera Malhotra, D.R
Section 115BSection 132(4)Section 250Section 69B

…k Setia V. Deputy Commissioner of Income Tax (2023) 155 Taxmann.com 293 (Amritsar – Trib) (v) Harish Sharma V. ITO (IT Appeal No.327 (Chd) of 2020, dt.11.05.2021 (vi) Daulatram Rawatmull V. CIT (1967) 64 ITR 593 (Calcutta) (vii) Mansfield & Sons V. CIT (1963) 48 ITR 254 (Calcutta) ITA Nos.1156 & 1163 to 1166/Bang/2023 M/s. S. Ramachandra Setty & Sons, Hassan Page 96 of 104 (viii) Sham Jewellers V. Dy.CIT (IT Appeal No.375 (Chad) of 2022, dt.22.08.2022 (c)The learned Commissioner of Income Tax (Appeals)-2, Panaji, Goa, has erred in ignoring the position of law that, as far as the provisions of section 115BBE of…

INCOME TAX OFFICER, W-1, VIJAYANAGAR vs. RAMACHANDRA SETTY AND SONS, HASSAN

In the result, appeal of the assessee in ITA

ITA 1165/BANG/2023[2015-16]Status: DisposedITAT Bangalore10 Jun 2024AY 2015-16

Bench: Shri Chandra Poojari & Shri Keshav Dubey

For Appellant: Shri C. Ramesh, A.RFor Respondent: Ms. Neera Malhotra, D.R
Section 115BSection 132(4)Section 250Section 69B

…k Setia V. Deputy Commissioner of Income Tax (2023) 155 Taxmann.com 293 (Amritsar – Trib) (v) Harish Sharma V. ITO (IT Appeal No.327 (Chd) of 2020, dt.11.05.2021 (vi) Daulatram Rawatmull V. CIT (1967) 64 ITR 593 (Calcutta) (vii) Mansfield & Sons V. CIT (1963) 48 ITR 254 (Calcutta) ITA Nos.1156 & 1163 to 1166/Bang/2023 M/s. S. Ramachandra Setty & Sons, Hassan Page 96 of 104 (viii) Sham Jewellers V. Dy.CIT (IT Appeal No.375 (Chad) of 2022, dt.22.08.2022 (c)The learned Commissioner of Income Tax (Appeals)-2, Panaji, Goa, has erred in ignoring the position of law that, as far as the provisions of section 115BBE of…

INCOME TAX OFFICER WARD-1 HASSAN, HASSAN vs. RAMACHANDRA SETTY AND SONGS, HASSAN

In the result, appeal of the assessee in ITA

ITA 1164/BANG/2023[2014-15]Status: DisposedITAT Bangalore10 Jun 2024AY 2014-15

Bench: Shri Chandra Poojari & Shri Keshav Dubey

For Appellant: Shri C. Ramesh, A.RFor Respondent: Ms. Neera Malhotra, D.R
Section 115BSection 132(4)Section 250Section 69B

…k Setia V. Deputy Commissioner of Income Tax (2023) 155 Taxmann.com 293 (Amritsar – Trib) (v) Harish Sharma V. ITO (IT Appeal No.327 (Chd) of 2020, dt.11.05.2021 (vi) Daulatram Rawatmull V. CIT (1967) 64 ITR 593 (Calcutta) (vii) Mansfield & Sons V. CIT (1963) 48 ITR 254 (Calcutta) ITA Nos.1156 & 1163 to 1166/Bang/2023 M/s. S. Ramachandra Setty & Sons, Hassan Page 96 of 104 (viii) Sham Jewellers V. Dy.CIT (IT Appeal No.375 (Chad) of 2022, dt.22.08.2022 (c)The learned Commissioner of Income Tax (Appeals)-2, Panaji, Goa, has erred in ignoring the position of law that, as far as the provisions of section 115BBE of…

INCOME TAX OFFICER, W-1, HASSAN vs. RAMACHANDRA SETTY & SONS, HASSAN

In the result, appeal of the assessee in ITA

ITA 1163/BANG/2023[2013-14]Status: DisposedITAT Bangalore10 Jun 2024AY 2013-14

Bench: Shri Chandra Poojari & Shri Keshav Dubey

For Appellant: Shri C. Ramesh, A.RFor Respondent: Ms. Neera Malhotra, D.R
Section 115BSection 132(4)Section 250Section 69B

…k Setia V. Deputy Commissioner of Income Tax (2023) 155 Taxmann.com 293 (Amritsar – Trib) (v) Harish Sharma V. ITO (IT Appeal No.327 (Chd) of 2020, dt.11.05.2021 (vi) Daulatram Rawatmull V. CIT (1967) 64 ITR 593 (Calcutta) (vii) Mansfield & Sons V. CIT (1963) 48 ITR 254 (Calcutta) ITA Nos.1156 & 1163 to 1166/Bang/2023 M/s. S. Ramachandra Setty & Sons, Hassan Page 96 of 104 (viii) Sham Jewellers V. Dy.CIT (IT Appeal No.375 (Chad) of 2022, dt.22.08.2022 (c)The learned Commissioner of Income Tax (Appeals)-2, Panaji, Goa, has erred in ignoring the position of law that, as far as the provisions of section 115BBE of…

M/S. S. RAMASHANDRA SETTY & SONS,HASSAN vs. INCOME TAX OFFICER, WARD-1 , HASSAN

In the result, appeal of the assessee in ITA

ITA 1156/BANG/2023[2017-18]Status: DisposedITAT Bangalore10 Jun 2024AY 2017-18

Bench: Shri Chandra Poojari & Shri Keshav Dubey

For Appellant: Shri C. Ramesh, A.RFor Respondent: Ms. Neera Malhotra, D.R
Section 115BSection 132(4)Section 250Section 69B

…k Setia V. Deputy Commissioner of Income Tax (2023) 155 Taxmann.com 293 (Amritsar – Trib) (v) Harish Sharma V. ITO (IT Appeal No.327 (Chd) of 2020, dt.11.05.2021 (vi) Daulatram Rawatmull V. CIT (1967) 64 ITR 593 (Calcutta) (vii) Mansfield & Sons V. CIT (1963) 48 ITR 254 (Calcutta) ITA Nos.1156 & 1163 to 1166/Bang/2023 M/s. S. Ramachandra Setty & Sons, Hassan Page 96 of 104 (viii) Sham Jewellers V. Dy.CIT (IT Appeal No.375 (Chad) of 2022, dt.22.08.2022 (c)The learned Commissioner of Income Tax (Appeals)-2, Panaji, Goa, has erred in ignoring the position of law that, as far as the provisions of section 115BBE of…

SANJEEV KUMAR GOYAL,FATEHABAD vs. DCIT, CC-2, LUDHIANA

In the result, the appeal of the assesse is allowed

ITA 80/CHANDI/2023[2019-20]Status: DisposedITAT Chandigarh22 May 2024AY 2019-20

Bench: This Hon’Ble Tribunal Under Section 253 Of The Income Tax Act, 1961 As Amended From Time To Time. 2. The Assessee Is Aggrieved By The Order Of The Ld. Cit(A) Dt. 20/01/2023 In Appeal No. 10853/2018-19/It/Cit(A)-5/Ldh/2021-22 For The A.Y. 2019-20 Under Section 250(6) Of The Income Tax Act, 1961 Which Was Dismissed. Therefore The Present Second Appeal Under Section 253 Of The Income Tax Act, 1961 Before Us Against The Aforesaid Order Dt. 20/01/2023 Which Is Hereinafter Referred To As The Impugned Order.

For Appellant: Shri Sudhir Sehgal, Advocate and Shri Rishaba Marwaha, C.AFor Respondent: Shri Dharamvir, JCIT, Sr. DR
Section 143(2)Section 250(6)Section 253Section 68

…e appreciated that in DDK Spinning Mills judgment (supra) reliance is placed on two judgments of Hon’ble Calcutta High Court in case of Daulatram Rawatmull Vs. CIT reported in (1967) 64 ITR 593(Cal) and in case of Mansfiled and Sons Vs. CIT reported in (1963) 48 ITR 254(Cal) wherein following ratio is cuddled out: “ In the instant case the assesse is a firm formed for the purpose of carrying on business. There is nothing on record to show that the firm had any source of income other than business. Therefore, in our opinion, it is not unreasonable to hold that any amount representing secret income arose out of the…

SH. KRISHAN KUMAR,KHANNA vs. DCIT, CC-1, LUDHIANA

In the result, the appeal of the Assessee is allowed

ITA 175/CHANDI/2023[2019-20]Status: DisposedITAT Chandigarh04 Jan 2024AY 2019-20

Bench: Shri A.D. Jain & Shri Vikram Singh Yadav

For Appellant: Shri Sudhir Sehgal, AdvFor Respondent: Shri Anil Sharma, JCIT, Sr.DR
Section 115BSection 133ASection 139Section 143(1)Section 143(2)Section 68Section 69Section 69ASection 69BSection 69C

…Pvt. Ltd. as well as Gujarat High Court in case of Fakir Mohmed Haji Hasan Vs CIT. 10. Further reliance was placed on the judgement of the Hon'ble Calcutta High Court in the cases of ‘DaulatramRawatmull vs. CIT’, 64 ITR 593, in ‘Mansfeild and Sons vs. CIT’, 48 ITR 254 (Cal.), and Coordinate Chandigarh Benches decision in cases of ‘M/s Sham Jewellers Vs. The DCIT’, (in ITA No. 375/Chd/2022, ‘M/s Sham Fashion Mall’ in ITA 315/Chd/2022, ‘Bajaj Sons Ltd.’, (ITA No. 1127/Chd/2019)’, ‘DCIT vs. M/s Khurana Rolling Pvt Ltd’ 175-Chd-2023– Shri Krishan Kumar, Khanna 24 (ITA No. 745/Chd/2017) and some other decisions…

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(vi) Daulatram Rawatmull v. CIT (48 ITR 254) — Cited in 27 Judgments | BharatTax