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“on-money”

Cash Credits & Unexplained ItemsSection 69BSection 69B1,574 judgments

DCIT, CENTRAL CIRCLE-30, NEW DELHI vs. SHALIMAR CORP. LTD, MUMBAI

In the result, the appeal of the assessee in ITA No

ITA 3068/DEL/2022[2017-18]Status: DisposedITAT Delhi09 Apr 2026AY 2017-18

Bench: Ms. Madhumita Roy & Shri Naveen Chandra

For Appellant: Shri Subhash Aggarwal, AdvFor Respondent: Shri Mahesh Rajani, CIT-DR
Section 143(3)Section 153ASection 68

department on 18.06.2015 during which various documents/evidence were found Page 2 of 19 ITA No. 3068/DEL/2022 Shalimar Corp [A.Y. 2017-18) regarding receipts of on-money payments in their real estate business. The Assessing Officer passed order u/s 153A of the Act for the preceding six years from the year ... regard to the year of search that is A.Y 2016-2017 making additions on account of computation of on-money on the basis of the special auditors' report of Rs 197.82 crore plus Rs 101.02 crore as declared during the search; on account of loans taken, share capital raised

SHALIMAR CORP LTD,LUCKNOW vs. DCIT, CENTRAL CIRCLE-30, NEW DELHI

In the result, the appeal of the assessee in ITA No

ITA 2769/DEL/2022[2017-18]Status: DisposedITAT Delhi09 Apr 2026AY 2017-18

Bench: Ms. Madhumita Roy & Shri Naveen Chandra

For Appellant: Shri Subhash Aggarwal, AdvFor Respondent: Shri Mahesh Rajani, CIT-DR
Section 143(3)Section 153ASection 68

department on 18.06.2015 during which various documents/evidence were found Page 2 of 19 ITA No. 3068/DEL/2022 Shalimar Corp [A.Y. 2017-18) regarding receipts of on-money payments in their real estate business. The Assessing Officer passed order u/s 153A of the Act for the preceding six years from the year ... regard to the year of search that is A.Y 2016-2017 making additions on account of computation of on-money on the basis of the special auditors' report of Rs 197.82 crore plus Rs 101.02 crore as declared during the search; on account of loans taken, share capital raised

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

deleting the AO to tax the unaccounted profit in the\nyear in which sale deed is executed instead of the year in which the on-money has been\nreceived, ignoring that the same is not in accordance with Accounting principles as per\nICDS-3 applicable to Real Estate Developers ... also not appreciating that the income\non account of undisclosed on-money receipt was required to be assessed in the year of\nreceipt.\n(This is revenue's ground no. 2 in ITA No. 665/RJT/2024 for AY 2022-23)\n4.The relevant material facts, as culled out from the material

DEEPAK MOHANLAL PURUSWANI,RAJKOT vs. DCIT, CC-1, RAJKOT, RAJKOT

ITA 631/RJT/2024[2022-23]Status: DisposedITAT Rajkot13 Mar 2026AY 2022-23

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinhaआयकर अपील सं/.Ita No.630 & 631/Rjt/2024 िनधा"रण वष"/ Assessment Year: (2021-2022 & 2022-23) Hybrid Hearing बनाम Shree Deepak Mohanlal Puruswani The Dcit, Cc-1 Rajkot Nr. Maa Krupa, 4- Saurashtra Kala Vs. Aaykar Bhawan “Amruta Estate”, Kendra Society, Opp. Nirmala Convent, Mg Road, Rajkot 360001, Kalawad Road, Rajkot-360001 "थायीलेखासं/.जीआइआरसं/.Pan No. : Ajvpp5139P .. (अपीलाथ"/Appellant) (""यथ"/Respondent) आयकर अपील सं/.Ita No.665/Rjt/2024 िनधा"रण वष"/ Assessment Year: (2022-23) बनाम The Dcit, Cc-1 Rajkot Shree Deepak Mohanlal Puruswani Aaykar Bhawan“Amruta Estate”, 2Nd Vs. Nr. Maa Krupa, 4- Saurashtra Kala Floor Mg Road Kendra Society, Opp. Nirmala Rajkot 360001, Gujrat Convent, Kalawad Road, Rajkot-360001 "थायीलेखासं/.जीआइआरसं/.Pan No. : Ajvpp5139P .. (अपीलाथ"/Appellant) (""यथ"/Respondent)

For Appellant: Shri Mehul Ranpura, Ld. ARFor Respondent: Shri Abhimanyu Singh Yadav, Ld. SR. DR
Section 143(3)Section 250

deleting the AO to tax the unaccounted profit in the year in which sale deed is executed instead of the year in which the on-money has been received, ignoring that the same is not in accordance with Accounting principles as per Page ... 665/Rjt/2024 Deepak Mohanlal Puruswani ICDS-3 applicable to Real Estate Developers and also not appreciating that the income on account of undisclosed on-money receipt was required to be assessed in the year of receipt. (This is revenue's ground no. 2 in ITA No. 665/RJT/2024

DEEPAK MOHANLAL PURUSWANI,RAJKOT vs. DCIT, CC-1, RAJKOT, RAJKOT

ITA 630/RJT/2024[2021-22]Status: DisposedITAT Rajkot13 Mar 2026AY 2021-22

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinhaआयकर अपील सं/.Ita No.630 & 631/Rjt/2024 िनधा"रण वष"/ Assessment Year: (2021-2022 & 2022-23) Hybrid Hearing बनाम Shree Deepak Mohanlal Puruswani The Dcit, Cc-1 Rajkot Nr. Maa Krupa, 4- Saurashtra Kala Vs. Aaykar Bhawan “Amruta Estate”, Kendra Society, Opp. Nirmala Convent, Mg Road, Rajkot 360001, Kalawad Road, Rajkot-360001 "थायीलेखासं/.जीआइआरसं/.Pan No. : Ajvpp5139P .. (अपीलाथ"/Appellant) (""यथ"/Respondent) आयकर अपील सं/.Ita No.665/Rjt/2024 िनधा"रण वष"/ Assessment Year: (2022-23) बनाम The Dcit, Cc-1 Rajkot Shree Deepak Mohanlal Puruswani Aaykar Bhawan“Amruta Estate”, 2Nd Vs. Nr. Maa Krupa, 4- Saurashtra Kala Floor Mg Road Kendra Society, Opp. Nirmala Rajkot 360001, Gujrat Convent, Kalawad Road, Rajkot-360001 "थायीलेखासं/.जीआइआरसं/.Pan No. : Ajvpp5139P .. (अपीलाथ"/Appellant) (""यथ"/Respondent)

For Appellant: Shri Mehul Ranpura, Ld. ARFor Respondent: Shri Abhimanyu Singh Yadav, Ld. SR. DR
Section 143(3)Section 250

deleting the AO to tax the unaccounted profit in the year in which sale deed is executed instead of the year in which the on-money has been received, ignoring that the same is not in accordance with Accounting principles as per Page ... 665/Rjt/2024 Deepak Mohanlal Puruswani ICDS-3 applicable to Real Estate Developers and also not appreciating that the income on account of undisclosed on-money receipt was required to be assessed in the year of receipt. (This is revenue's ground no. 2 in ITA No. 665/RJT/2024

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(4), AHMEDABAD, AHMEDABAD vs. SAFAL ENGINEERS AND REALTIES LLP, AHMEDABAD

In the result, the appeal of the assessee is partly allowed while the appeal\nof the Revenue is dismissed

ITA 1731/AHD/2024[2022-23]Status: DisposedITAT Ahmedabad13 Mar 2026AY 2022-23
Section 143(3)

submitted by the appellant during the course of appellate proceedings.\n3. The Ld. CIT(A) has erred in law and on facts in estimating on-money for all units sold in the project “Seventy” by relying upon stray loose paper found during the course of search from City Estate Management ... considering that all those seized loose papers are dumb document in absence of any members diary, cash vouchers, members ledger account for any alleged on-money, signature of any member, any cross enquiry being made with any members whose names are jotted on the seized loose papers, any confirmation

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(4), AHMEDABAD, AHMEDABAD vs. SAFAL ENGINEERS AND REALTIES LLP, AHMEDABAD

In the result, the appeal of the assessee is partly allowed while the appeal\nof the Revenue is dismissed

ITA 1730/AHD/2024[2021-22]Status: DisposedITAT Ahmedabad13 Mar 2026AY 2021-22
Section 143(3)

nappellant during the course of appellate proceedings.\n\n3. The Ld. CIT(A) has erred in law and on facts in estimating on-money\nfor all units sold in the project “Seventy” by relying upon stray loose\npaper found during the course of search from City Estate Management\nand VineetKanodia ... considering that all those seized loose\npapers are dumb document in absence of any members diary, cash\nvouchers, members ledger account for any alleged on-money,\nsignature of any member, any cross enquiry being made with any\nmembers whose names are jotted on the seized loose papers, any\nconfirmation

SAFAL ENGINEERS AND REALTIES LLP,AHMEDABAD vs. THE DY.CIT, CENTRAL CIRCLE-1(4), AHMEDABAD

The appeal of the assessee is partly allowed while the appeal\nof the Revenue is dismissed

ITA 1700/AHD/2024[2022-23]Status: DisposedITAT Ahmedabad13 Mar 2026AY 2022-23
Section 143(3)

nappellant during the course of appellate proceedings.\n\n3. The Ld. CIT(A) has erred in law and on facts in estimating on-money\nfor all units sold in the project “Seventy” by relying upon stray loose\npaper found during the course of search from City Estate Management\nand VineetKanodia ... considering that all those seized loose\npapers are dumb document in absence of any members diary, cash\nvouchers, members ledger account for any alleged on-money,\nsignature of any member, any cross enquiry being made with any\nmembers whose names are jotted on the seized loose papers, any\nconfirmation

SAFAL ENGINEERS AND REALTIES LLP,AHMEDABAD vs. THE ACIT, CENTRAL CIRCLE-1(4), AHMEDABAD

In the result, the appeal of the assessee is partly allowed while the appeal\nof the Revenue is dismissed

ITA 1699/AHD/2024[2021-22]Status: DisposedITAT Ahmedabad13 Mar 2026AY 2021-22
Section 143(3)

nappellant during the course of appellate proceedings.\n\n3.\nThe Ld. CIT(A) has erred in law and on facts in estimating on-money\nfor all units sold in the project “Seventy” by relying upon stray loose\npaper found during the course of search from City Estate Management\nand VineetKanodia ... considering that all those seized loose\npapers are dumb document in absence of any members diary, cash\nvouchers, members ledger account for any alleged on-money,\nsignature of any member, any cross enquiry being made with any\nmembers whose names are jotted on the seized loose papers, any\nconfirmation

KRISH PACKAGING PVT LTD,NEW DELHI vs. DCIT CENTRAL CIRCLE, NOIDA

ITA 3942/DEL/2019[2011-12]Status: DisposedITAT Delhi13 Mar 2026AY 2011-12

Bench: Shri Anubhav Sharma & Shri Naveen Chandrakrish Packaging Pvt. Ltd. Vs. Dcit, Central Circle F-11, Basement Green Sector -33, Noida Park, Extension , Uttar Pradesh – 201307 New Delhi – 110016 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aacck8980A Appellant .. Respondent

For Appellant: Sh. Salil Aggarwal, Sr. AdvFor Respondent: Sh. Dayainder Singh Sidhu, CIT
Section 143(3)Section 153CSection 69

this AY and how the income of this AY is impacted. To be more precise as to how the incriminating documents indicated payment of on-money during the FY: 2010-11 for which search assessment for AY: 2011-12 is to be initiated. P a g e | 5 Krish Packaging

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

nand Highstreet Business Bay is the first project of the firm.\n2. In the show cause notice, it is alleged that we have paid on-money of Rs.\n16,87,50,000/- during the year for purchase of the land. Further, it is also alleged that\nwe have received total ... on-money of Rs.6,55,22,200/- (Rs.1,05,00,000 in FY 19-20; Rs.\n1,20,00,000/- in FY 20-21 and Rs.4,30,22,200/- in FY 21-22)\n3. Thus, as per the notice also, the firm had received on money of Rs.2

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

nand Highstreet Business Bay is the first project of the firm.\n2. In the show cause notice, it is alleged that we have paid on-money of Rs.\n16,87,50,000/- during the year for purchase of the land. Further, it is also alleged that\nwe have received total ... on-money of Rs.6,55,22,200/- (Rs.1,05,00,000 in FY 19-20; Rs.\n1,20,00,000/- in FY 20-21 and Rs.4,30,22,200/- in FY 21-22)\n3. Thus, as per the notice also, the firm had received on money of Rs.2

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

nand Highstreet Business Bay is the first project of the firm.\n2. In the show cause notice, it is alleged that we have paid on-money of Rs.\n16,87,50,000/- during the year for purchase of the land. Further, it is also alleged that\nwe have received total ... on-money of Rs.6,55,22,200/- (Rs.1,05,00,000 in FY 19-20; Rs.\n1,20,00,000/- in FY 20-21 and Rs.4,30,22,200/- in FY 21-22)\n3. Thus, as per the notice also, the firm had received on money of Rs.2

ASSISTANT COMMISSIONER OF INCOME TAX, CHANDIGARH vs. SARAF THE JEWELLERS, PUNJAB

Appeal stand dismissed

ITA 1594/CHANDI/2025[2021-22]Status: DisposedITAT Chandigarh12 Mar 2026AY 2021-22

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am 1. आयकरअपीलसं. / Ita No.1232/Chandi/2025 (िनधा"रणवष" / Assessment Year: 2021-22) Saraf The Jeweller Dcit / Acit (Central)-2 बनाम/ Sco 45, Pocket No.1 C.R. Building Nac Showroom, Manimajra Himalaya Marg, Vs. Chandigarh – 160101 Sector-17E, Chandigarh "थायीलेखासं./जीआइआरसं./Pan/Gir No. Adafs-2345-B (अपीलाथ"/Appellant) : (""थ" / Respondent) & 2. आयकरअपीलसं. / Ita No.1594/Chandi/2025 (िनधा"रणवष" / Assessment Year: 2021-22) Dcit / Acit (Central)-2 Saraf The Jeweller बनाम/ C.R. Building Sco 45, Pocket No.1 Himalaya Marg, Nac Showroom, Manimajra Vs. Sector-17E, Chandigarh Chandigarh – 160101 "थायीलेखासं./जीआइआरसं./Pan/Gir No. Adafs-2345-B (अपीलाथ"/Appellant) : (""थ" / Respondent) Assessee By : Sh. Sudhir Sehgal (Advocate) & Sh. Sahil Ratra (Advocate) – Ld. Ars Revenue By : Sh. Abhishek Pal Garg (Cit) & Dr. Ranjit Kaur (Addl. Cit) – Ld. Drs सुनवाईकीतारीख/Date Of Hearing : 12.02.2026 घोषणाकीतारीख /Date Of Pronouncement 12.03.2026 : आदेश / O R D E R Per Bench

For Appellant: Sh. Sudhir Sehgal (Advocate) and Sh. Sahil RatraFor Respondent: Sh. Abhishek Pal Garg (CIT) & Dr. Ranjit Kaur (Addl
Section 115BSection 143(3)Section 65BSection 69C

difference was computed. The statement of one Shri Santokh Singh, as recorded by investigation wing, was referred to support the allegation of receipt of on-money. In the above background, Ld. AO tabulated variation in 41 sale instances and the suppression of sales was quantified ... challenged quantum additions on merits. The Ld. CIT(A), after due consideration thereof as well as material on record, upheld the addition of alleged on-money for Rs.1570.95 Lacs but deleted addition of Rs.957.05 Lacs which was made on the basis of extrapolation. The same form subject matter of cross

ASSISTANT COMMISSIONER OF INCOME TAX, CHANDIGARH vs. SARAF THE JEWELLERS, PUNJAB

Appeal stand dismissed

ITA 1593/CHANDI/2025[2020-21]Status: DisposedITAT Chandigarh12 Mar 2026AY 2020-21

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am 1. आयकरअपीलसं. / Ita No.1231/Chandi/2025 (िनधा"रणवष" / Assessment Year: 2020-21) Saraf The Jeweller Dcit / Acit (Central)-2 बनाम/ Sco 45, Pocket No.1 C.R. Building Nac Showroom, Manimajra Himalaya Marg, Vs. Chandigarh – 160101 Sector-17E, Chandigarh "थायीलेखासं./जीआइआरसं./Pan/Gir No. Adafs-2345-B (अपीलाथ"/Appellant) : (""थ" / Respondent) & 2. आयकरअपीलसं. / Ita No.1593/Chandi/2025 (िनधा"रणवष" / Assessment Year: 2020-21) Dcit / Acit (Central)-2 Saraf The Jeweller बनाम/ C.R. Building Sco 45, Pocket No.1 Himalaya Marg, Nac Showroom, Manimajra Vs. Sector-17E, Chandigarh Chandigarh – 160101 "थायीलेखासं./जीआइआरसं./Pan/Gir No. Adafs-2345-B (अपीलाथ"/Appellant) : (""थ" / Respondent) अपीलाथ"कीओरसे/Appellant Sh. Sudhir Sehgal (Advocate) & Sh. Sahil Ratra (Advocate) – Ld. Ars By : ""थ"कीओरसे/Respondent By : Sh. Abhishek Pal Garg (Cit) & Dr. Ranjit Kaur (Addl. Cit) – Ld. Drs सुनवाईकीतारीख/Date Of Hearing : 12.02.2026 घोषणाकीतारीख /Date Of Pronouncement 11.03.2026 : आदेश / O R D E R Per Bench

For Respondent: Sh. Abhishek Pal Garg (CIT) & Dr. Ranjit Kaur (Addl. CIT) –
Section 115BSection 153A(1)(b)Section 153DSection 65BSection 68Section 69C

statement of one Shri Santokh Singh, as recorded by investigation wing, was referred to by Ld. AO to support the allegation of receipt of on-money. In the above background, Ld. AO tabulated variation in 41 sale instances 5 and the suppression of sales was quantified ... also quantum additions in merit. The Ld. CIT(A), after due consideration thereof as well as material on record, upheld the addition of alleged on-money for Rs.1302.90 Lacs but deleted addition of Rs.999.86 Lacs which was made on the basis of extrapolation. The same form subject matter of cross

SARAF THE JEWELLER, CHANDIGARH,CHANDIGARH vs. THE DCIT/ACIT CENTRAL CIRCLE- 2, CHANDIGARH, CHANDIGARH

Appeal stand dismissed

ITA 1232/CHANDI/2025[2021-22]Status: DisposedITAT Chandigarh12 Mar 2026AY 2021-22

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am 1. आयकरअपीलसं. / Ita No.1232/Chandi/2025 (िनधा"रणवष" / Assessment Year: 2021-22) Saraf The Jeweller Dcit / Acit (Central)-2 बनाम/ Sco 45, Pocket No.1 C.R. Building Nac Showroom, Manimajra Himalaya Marg, Vs. Chandigarh – 160101 Sector-17E, Chandigarh "थायीलेखासं./जीआइआरसं./Pan/Gir No. Adafs-2345-B (अपीलाथ"/Appellant) : (""थ" / Respondent) & 2. आयकरअपीलसं. / Ita No.1594/Chandi/2025 (िनधा"रणवष" / Assessment Year: 2021-22) Dcit / Acit (Central)-2 Saraf The Jeweller बनाम/ C.R. Building Sco 45, Pocket No.1 Himalaya Marg, Nac Showroom, Manimajra Vs. Sector-17E, Chandigarh Chandigarh – 160101 "थायीलेखासं./जीआइआरसं./Pan/Gir No. Adafs-2345-B (अपीलाथ"/Appellant) : (""थ" / Respondent) Assessee By : Sh. Sudhir Sehgal (Advocate) & Sh. Sahil Ratra (Advocate) – Ld. Ars Revenue By : Sh. Abhishek Pal Garg (Cit) & Dr. Ranjit Kaur (Addl. Cit) – Ld. Drs सुनवाईकीतारीख/Date Of Hearing : 12.02.2026 घोषणाकीतारीख /Date Of Pronouncement 12.03.2026 : आदेश / O R D E R Per Bench

For Appellant: Sh. Sudhir Sehgal (Advocate) and Sh. Sahil RatraFor Respondent: Sh. Abhishek Pal Garg (CIT) & Dr. Ranjit Kaur (Addl
Section 115BSection 143(3)Section 65BSection 69C

difference was computed. The statement of one Shri Santokh Singh, as recorded by investigation wing, was referred to support the allegation of receipt of on-money. In the above background, Ld. AO tabulated variation in 41 sale instances and the suppression of sales was quantified ... challenged quantum additions on merits. The Ld. CIT(A), after due consideration thereof as well as material on record, upheld the addition of alleged on-money for Rs.1570.95 Lacs but deleted addition of Rs.957.05 Lacs which was made on the basis of extrapolation. The same form subject matter of cross

SARAF THE JEWELLER, CHANDIGARH,CHANDIGARH vs. THE DCIT/ACIT CENTRAL CIRCLE -2, CHANDIGARH, CHANDIGARH

Appeal stand dismissed

ITA 1231/CHANDI/2025[2020-21]Status: DisposedITAT Chandigarh12 Mar 2026AY 2020-21

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am 1. आयकरअपीलसं. / Ita No.1231/Chandi/2025 (िनधा"रणवष" / Assessment Year: 2020-21) Saraf The Jeweller Dcit / Acit (Central)-2 बनाम/ Sco 45, Pocket No.1 C.R. Building Nac Showroom, Manimajra Himalaya Marg, Vs. Chandigarh – 160101 Sector-17E, Chandigarh "थायीलेखासं./जीआइआरसं./Pan/Gir No. Adafs-2345-B (अपीलाथ"/Appellant) : (""थ" / Respondent) & 2. आयकरअपीलसं. / Ita No.1593/Chandi/2025 (िनधा"रणवष" / Assessment Year: 2020-21) Dcit / Acit (Central)-2 Saraf The Jeweller बनाम/ C.R. Building Sco 45, Pocket No.1 Himalaya Marg, Nac Showroom, Manimajra Vs. Sector-17E, Chandigarh Chandigarh – 160101 "थायीलेखासं./जीआइआरसं./Pan/Gir No. Adafs-2345-B (अपीलाथ"/Appellant) : (""थ" / Respondent) अपीलाथ"कीओरसे/Appellant Sh. Sudhir Sehgal (Advocate) & Sh. Sahil Ratra (Advocate) – Ld. Ars By : ""थ"कीओरसे/Respondent By : Sh. Abhishek Pal Garg (Cit) & Dr. Ranjit Kaur (Addl. Cit) – Ld. Drs सुनवाईकीतारीख/Date Of Hearing : 12.02.2026 घोषणाकीतारीख /Date Of Pronouncement 11.03.2026 : आदेश / O R D E R Per Bench

For Respondent: Sh. Abhishek Pal Garg (CIT) & Dr. Ranjit Kaur (Addl. CIT) –
Section 115BSection 153A(1)(b)Section 153DSection 65BSection 68Section 69C

statement of one Shri Santokh Singh, as recorded by investigation wing, was referred to by Ld. AO to support the allegation of receipt of on-money. In the above background, Ld. AO tabulated variation in 41 sale instances 5 and the suppression of sales was quantified ... also quantum additions in merit. The Ld. CIT(A), after due consideration thereof as well as material on record, upheld the addition of alleged on-money for Rs.1302.90 Lacs but deleted addition of Rs.999.86 Lacs which was made on the basis of extrapolation. The same form subject matter of cross

BALWANT LAXMANJI PUROHIT,MUMBAI vs. DCIT CENTRAL CIRCLE 4(2), MUMBAI

In the result, all the three appeal

ITA 8454/MUM/2025[2019-2020]Status: DisposedITAT Mumbai12 Mar 2026AY 2019-2020

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal ()

For Appellant: Mr. Arun Kanti Datta, CIT-DRFor Respondent: Mr. Bharat Kumar
Section 153CSection 250

Platinum Mall" project of RHIL, various at for the "Platinum Mall" project of RHIL, various purchasers, including the present assessee, had paid "on-money" in purchasers, including the present assessee, had paid "on purchasers, including the present assessee, had paid "on cash, over and above the registered consideration. The aggregate ... addition of ₹2,00,000/ 2,00,000/- under section 69 of the Act towards under section 69 of the Act towards alleged on-money payment to RHIL. The addition so made by the money payment to RHIL. The addition so made by the money payment to RHIL. The addition

BALWANT LAXMANJI PUROHIT,MUMBAI vs. DCIT CENTRAL CIRCLE 4(2), MUMBAI

In the result, all the three appeal

ITA 8453/MUM/2025[2018-2019]Status: DisposedITAT Mumbai12 Mar 2026AY 2018-2019

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal ()

For Appellant: Mr. Arun Kanti Datta, CIT-DRFor Respondent: Mr. Bharat Kumar
Section 153CSection 250

Platinum Mall" project of RHIL, various at for the "Platinum Mall" project of RHIL, various purchasers, including the present assessee, had paid "on-money" in purchasers, including the present assessee, had paid "on purchasers, including the present assessee, had paid "on cash, over and above the registered consideration. The aggregate ... addition of ₹2,00,000/ 2,00,000/- under section 69 of the Act towards under section 69 of the Act towards alleged on-money payment to RHIL. The addition so made by the money payment to RHIL. The addition so made by the money payment to RHIL. The addition

BALWANT LAXMANJI PUROHIT,MUMBAI vs. DCIT CENTRAL CIRCLE 4(2), MUMBAI

In the result, all the three appeal

ITA 8452/MUM/2025[2017-2018]Status: DisposedITAT Mumbai12 Mar 2026AY 2017-2018

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal ()

For Appellant: Mr. Arun Kanti Datta, CIT-DRFor Respondent: Mr. Bharat Kumar
Section 153CSection 250

Platinum Mall" project of RHIL, various at for the "Platinum Mall" project of RHIL, various purchasers, including the present assessee, had paid "on-money" in purchasers, including the present assessee, had paid "on purchasers, including the present assessee, had paid "on cash, over and above the registered consideration. The aggregate ... addition of ₹2,00,000/ 2,00,000/- under section 69 of the Act towards under section 69 of the Act towards alleged on-money payment to RHIL. The addition so made by the money payment to RHIL. The addition so made by the money payment to RHIL. The addition

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