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“on money receipt”

Cash Credits & Unexplained ItemsSection 69BSection 69B350 judgments

The decision most relied on for on money receipt is Kale Khan Mohammad Hanif v. CIT (50 ITR 1), cited in 581 judgments on BharatTax.

Leading authorities on on money receipt

Kale Khan Mohammad Hanif v. CIT
50 ITR 1 · 1963 · Supreme Court
581
citing judgments

The assessee bears the onus of proving the source and nature of any sum of money or receipt found to have been received by them. If the assessee fails to satisfactorily explain the receipt, the Income-tax Officer is entitled to treat it as taxable income.

CIT v. President Industries
258 ITR 654 · 2002 · High Court
471
citing judgments

When books of account are rejected and unaccounted sales or receipts are discovered, the income addition is restricted to the net profit element embedded in these undisclosed transactions, not the entire sale proceeds or receipts, especially if corresponding purchases are not proven to be outside the books.

Sahney Steel and Press Works Ltd. v. CIT
228 ITR 253 · 1997 · Supreme Court
429
citing judgments

A subsidy is treated as a revenue receipt if the assessee is free to use the money in its business as it likes and is not obligated to spend it for a specific capital purpose, such as acquiring assets or repaying loans.

CIT v. Balchand Ajit Kumar
263 ITR 610 · 2003 · High Court
212
citing judgments

When making an addition for unaccounted receipts, on-money, or non-genuine purchases/sales, the addition should be restricted to the estimated profit element embedded in such transactions, rather than the entire gross amount, particularly when evidence of corresponding expenditure is incomplete. This estimation often involves applying a net profit rate.

CIT v. Girish Chaudhary
296 ITR 619 · 2008 · High Court
175
citing judgments

Additions to income cannot be made solely based on "dumb documents" or vague loose papers seized during a search that merely indicate rates without specific corroborative material linking them to the assessee's unaccounted transactions. The presumption under Section 292C may not apply to such documents.

CIT v. Maulikkumar K. Shah
307 ITR 137 · 2008 · High Court
166
citing judgments

Additions on account of on-money receipts cannot be justified solely based on loose papers or 'sauda-chithis' without evidence of actual payment or a clear indication of a completed transaction within those documents.

Glass Lines Equipments Company Ltd. v. CIT
253 ITR 454 · 2002 · High Court
150
citing judgments

The Assessing Officer cannot selectively accept parts of a statement or seized evidence that are favourable to the revenue while rejecting other parts favourable to the assessee without proper investigation; the evidence must be considered as a whole. Additions cannot be made based on mere presumptions or surmises without further inquiry.

CIT v. Gurubachhan Singh J. Juneja
302 ITR 63 · 2008 · High Court
147
citing judgments

When unaccounted receipts or suppressed sales are detected and books of account are rejected under Section 145(3), additions to income must be restricted to the profit element embedded in such transactions, not the entire transaction value. This profit element is to be estimated by considering the assessee's regular profit ratio as per books of account.

Judgments citing on money receipt

Naresh Organisers Pvt Ltd, Rajkot vs. ACIT, CC-1, Rajkot

ITA 527/RJT/2024[2022-23]Status: DisposedITAT Rajkot09 Mar 2026AY 2022-23

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinhaआयकर अपील सं/.Ita No.522 To 527/Rjt/2024 िनधा"रण वष"/ Assessment Year: (2017-2018 To 2022-23) बनाम Naresh Organisers Private Limited The Dcit, Cc-1 Rajkot Officer No. 702 R K Prime, 150 Feet Ring Vs. “Amruta Estate,” 2Nd Floor, Mg Road Next To Silver Heights, Nava Mava Road, Rajkot 360001, Gujrat Circle, Rajkot 360005, Gujrat /. /. Pan No. : Aaccn1282A "थायीलेखासं जीआइआरसं .. (अपीलाथ"/Appellant) (""यथ"/Respondent) आयकर अपील सं/.Ita No.503, 515 To 517/Rjt/2024 िनधा"रण वष"/ Assessment Year: (2018-19 To 2021-22) बनाम The Dcit, Cc-1 Rajkot Naresh Organisers Private Limited “Amruta Estate,” 2Nd Floor, Mg Vs. Officer No. 702 R K Prime, 150 Feet Road, Rajkot 360001, Gujrat Ring Road Next To Silver Heights, Nava Mava Circle, Rajkot 360005, Gujrat /. /. Pan No. : Aaccn1282A "थायीलेखासं जीआइआरसं .. (अपीलाथ"/Appellant) (""यथ"/Respondent)

For Appellant: Shri Mehul Ranapura, Ld. ARFor Respondent: Shri Sanjay Pungulia, Ld. CIT (DR)
Section 143(3)Section 147Section 148Section 250

erred on facts as also in law in retaining addition of Rs.4,98,910/- by estimating profit at 16% of so called on money receipt. The addition made is bad in law as also on facts therefore the same may kindly be deleted. Alternatively, the addition made by estimating rate ... with Accounting principles as per 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. 503/RJT/2024

Naresh Organisers Pvt Ltd., Rajkot vs. ACIT, CC-1, Rajkot

ITA 526/RJT/2024[2021-22]Status: DisposedITAT Rajkot09 Mar 2026AY 2021-22

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinhaआयकर अपील सं/.Ita No.522 To 527/Rjt/2024 िनधा"रण वष"/ Assessment Year: (2017-2018 To 2022-23) बनाम Naresh Organisers Private Limited The Dcit, Cc-1 Rajkot Officer No. 702 R K Prime, 150 Feet Ring Vs. “Amruta Estate,” 2Nd Floor, Mg Road Next To Silver Heights, Nava Mava Road, Rajkot 360001, Gujrat Circle, Rajkot 360005, Gujrat /. /. Pan No. : Aaccn1282A "थायीलेखासं जीआइआरसं .. (अपीलाथ"/Appellant) (""यथ"/Respondent) आयकर अपील सं/.Ita No.503, 515 To 517/Rjt/2024 िनधा"रण वष"/ Assessment Year: (2018-19 To 2021-22) बनाम The Dcit, Cc-1 Rajkot Naresh Organisers Private Limited “Amruta Estate,” 2Nd Floor, Mg Vs. Officer No. 702 R K Prime, 150 Feet Road, Rajkot 360001, Gujrat Ring Road Next To Silver Heights, Nava Mava Circle, Rajkot 360005, Gujrat /. /. Pan No. : Aaccn1282A "थायीलेखासं जीआइआरसं .. (अपीलाथ"/Appellant) (""यथ"/Respondent)

For Appellant: Shri Mehul Ranapura, Ld. ARFor Respondent: Shri Sanjay Pungulia, Ld. CIT (DR)
Section 143(3)Section 147Section 148Section 250

erred on facts as also in law in retaining addition of Rs.4,98,910/- by estimating profit at 16% of so called on money receipt. The addition made is bad in law as also on facts therefore the same may kindly be deleted. Alternatively, the addition made by estimating rate ... with Accounting principles as per 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. 503/RJT/2024

Naresh Organisers Pvt Ltd, Rajkot vs. ACIT, CC-1, Rajkot

ITA 525/RJT/2024[2020-21]Status: DisposedITAT Rajkot09 Mar 2026AY 2020-21

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinhaआयकर अपील सं/.Ita No.522 To 527/Rjt/2024 िनधा"रण वष"/ Assessment Year: (2017-2018 To 2022-23) बनाम Naresh Organisers Private Limited The Dcit, Cc-1 Rajkot Officer No. 702 R K Prime, 150 Feet Ring Vs. “Amruta Estate,” 2Nd Floor, Mg Road Next To Silver Heights, Nava Mava Road, Rajkot 360001, Gujrat Circle, Rajkot 360005, Gujrat /. /. Pan No. : Aaccn1282A "थायीलेखासं जीआइआरसं .. (अपीलाथ"/Appellant) (""यथ"/Respondent) आयकर अपील सं/.Ita No.503, 515 To 517/Rjt/2024 िनधा"रण वष"/ Assessment Year: (2018-19 To 2021-22) बनाम The Dcit, Cc-1 Rajkot Naresh Organisers Private Limited “Amruta Estate,” 2Nd Floor, Mg Vs. Officer No. 702 R K Prime, 150 Feet Road, Rajkot 360001, Gujrat Ring Road Next To Silver Heights, Nava Mava Circle, Rajkot 360005, Gujrat /. /. Pan No. : Aaccn1282A "थायीलेखासं जीआइआरसं .. (अपीलाथ"/Appellant) (""यथ"/Respondent)

For Appellant: Shri Mehul Ranapura, Ld. ARFor Respondent: Shri Sanjay Pungulia, Ld. CIT (DR)
Section 143(3)Section 147Section 148Section 250

erred on facts as also in law in retaining addition of Rs.4,98,910/- by estimating profit at 16% of so called on money receipt. The addition made is bad in law as also on facts therefore the same may kindly be deleted. Alternatively, the addition made by estimating rate ... with Accounting principles as per 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. 503/RJT/2024

Naresh Organisers Pvt Ltd, Rajkot vs. ACIT, CC-1, Rajkot

ITA 524/RJT/2024[2019-20]Status: DisposedITAT Rajkot09 Mar 2026AY 2019-20

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinhaआयकर अपील सं/.Ita No.522 To 527/Rjt/2024 िनधा"रण वष"/ Assessment Year: (2017-2018 To 2022-23) बनाम Naresh Organisers Private Limited The Dcit, Cc-1 Rajkot Officer No. 702 R K Prime, 150 Feet Ring Vs. “Amruta Estate,” 2Nd Floor, Mg Road Next To Silver Heights, Nava Mava Road, Rajkot 360001, Gujrat Circle, Rajkot 360005, Gujrat /. /. Pan No. : Aaccn1282A "थायीलेखासं जीआइआरसं .. (अपीलाथ"/Appellant) (""यथ"/Respondent) आयकर अपील सं/.Ita No.503, 515 To 517/Rjt/2024 िनधा"रण वष"/ Assessment Year: (2018-19 To 2021-22) बनाम The Dcit, Cc-1 Rajkot Naresh Organisers Private Limited “Amruta Estate,” 2Nd Floor, Mg Vs. Officer No. 702 R K Prime, 150 Feet Road, Rajkot 360001, Gujrat Ring Road Next To Silver Heights, Nava Mava Circle, Rajkot 360005, Gujrat /. /. Pan No. : Aaccn1282A "थायीलेखासं जीआइआरसं .. (अपीलाथ"/Appellant) (""यथ"/Respondent)

For Appellant: Shri Mehul Ranapura, Ld. ARFor Respondent: Shri Sanjay Pungulia, Ld. CIT (DR)
Section 143(3)Section 147Section 148Section 250

erred on facts as also in law in retaining addition of Rs.4,98,910/- by estimating profit at 16% of so called on money receipt. The addition made is bad in law as also on facts therefore the same may kindly be deleted. Alternatively, the addition made by estimating rate ... with Accounting principles as per 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. 503/RJT/2024

Naresh Organisers Pvt Ltd, Rajkot vs. ACIT, CC-1, Rajkot

ITA 523/RJT/2024[2018-19]Status: DisposedITAT Rajkot09 Mar 2026AY 2018-19

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinhaआयकर अपील सं/.Ita No.522 To 527/Rjt/2024 िनधा"रण वष"/ Assessment Year: (2017-2018 To 2022-23) बनाम Naresh Organisers Private Limited The Dcit, Cc-1 Rajkot Officer No. 702 R K Prime, 150 Feet Ring Vs. “Amruta Estate,” 2Nd Floor, Mg Road Next To Silver Heights, Nava Mava Road, Rajkot 360001, Gujrat Circle, Rajkot 360005, Gujrat /. /. Pan No. : Aaccn1282A "थायीलेखासं जीआइआरसं .. (अपीलाथ"/Appellant) (""यथ"/Respondent) आयकर अपील सं/.Ita No.503, 515 To 517/Rjt/2024 िनधा"रण वष"/ Assessment Year: (2018-19 To 2021-22) बनाम The Dcit, Cc-1 Rajkot Naresh Organisers Private Limited “Amruta Estate,” 2Nd Floor, Mg Vs. Officer No. 702 R K Prime, 150 Feet Road, Rajkot 360001, Gujrat Ring Road Next To Silver Heights, Nava Mava Circle, Rajkot 360005, Gujrat /. /. Pan No. : Aaccn1282A "थायीलेखासं जीआइआरसं .. (अपीलाथ"/Appellant) (""यथ"/Respondent)

For Appellant: Shri Mehul Ranapura, Ld. ARFor Respondent: Shri Sanjay Pungulia, Ld. CIT (DR)
Section 143(3)Section 147Section 148Section 250

erred on facts as also in law in retaining addition of Rs.4,98,910/- by estimating profit at 16% of so called on money receipt. The addition made is bad in law as also on facts therefore the same may kindly be deleted. Alternatively, the addition made by estimating rate ... with Accounting principles as per 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. 503/RJT/2024

Naresh Organisers Pvt Ltd, Rajkot vs. ACIT, CC-1, Rajkot

ITA 522/RJT/2024[2017-18]Status: DisposedITAT Rajkot09 Mar 2026AY 2017-18

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinhaआयकर अपील सं/.Ita No.522 To 527/Rjt/2024 िनधा"रण वष"/ Assessment Year: (2017-2018 To 2022-23) बनाम Naresh Organisers Private Limited The Dcit, Cc-1 Rajkot Officer No. 702 R K Prime, 150 Feet Ring Vs. “Amruta Estate,” 2Nd Floor, Mg Road Next To Silver Heights, Nava Mava Road, Rajkot 360001, Gujrat Circle, Rajkot 360005, Gujrat /. /. Pan No. : Aaccn1282A "थायीलेखासं जीआइआरसं .. (अपीलाथ"/Appellant) (""यथ"/Respondent) आयकर अपील सं/.Ita No.503, 515 To 517/Rjt/2024 िनधा"रण वष"/ Assessment Year: (2018-19 To 2021-22) बनाम The Dcit, Cc-1 Rajkot Naresh Organisers Private Limited “Amruta Estate,” 2Nd Floor, Mg Vs. Officer No. 702 R K Prime, 150 Feet Road, Rajkot 360001, Gujrat Ring Road Next To Silver Heights, Nava Mava Circle, Rajkot 360005, Gujrat /. /. Pan No. : Aaccn1282A "थायीलेखासं जीआइआरसं .. (अपीलाथ"/Appellant) (""यथ"/Respondent)

For Appellant: Shri Mehul Ranapura, Ld. ARFor Respondent: Shri Sanjay Pungulia, Ld. CIT (DR)
Section 143(3)Section 147Section 148Section 250

erred on facts as also in law in retaining addition of Rs.4,98,910/- by estimating profit at 16% of so called on money receipt. The addition made is bad in law as also on facts therefore the same may kindly be deleted. Alternatively, the addition made by estimating rate ... with Accounting principles as per 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. 503/RJT/2024

DCIT, Central Circle 1, Rajkot vs. Naresh Organisers Pvt. Ltd., Rajkot

ITA 517/RJT/2024[2021-22]Status: DisposedITAT Rajkot09 Mar 2026AY 2021-22

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinhaआयकर अपील सं/.Ita No.522 To 527/Rjt/2024 िनधा"रण वष"/ Assessment Year: (2017-2018 To 2022-23) बनाम Naresh Organisers Private Limited The Dcit, Cc-1 Rajkot Officer No. 702 R K Prime, 150 Feet Ring Vs. “Amruta Estate,” 2Nd Floor, Mg Road Next To Silver Heights, Nava Mava Road, Rajkot 360001, Gujrat Circle, Rajkot 360005, Gujrat /. /. Pan No. : Aaccn1282A "थायीलेखासं जीआइआरसं .. (अपीलाथ"/Appellant) (""यथ"/Respondent) आयकर अपील सं/.Ita No.503, 515 To 517/Rjt/2024 िनधा"रण वष"/ Assessment Year: (2018-19 To 2021-22) बनाम The Dcit, Cc-1 Rajkot Naresh Organisers Private Limited “Amruta Estate,” 2Nd Floor, Mg Vs. Officer No. 702 R K Prime, 150 Feet Road, Rajkot 360001, Gujrat Ring Road Next To Silver Heights, Nava Mava Circle, Rajkot 360005, Gujrat /. /. Pan No. : Aaccn1282A "थायीलेखासं जीआइआरसं .. (अपीलाथ"/Appellant) (""यथ"/Respondent)

For Appellant: Shri Mehul Ranapura, Ld. ARFor Respondent: Shri Sanjay Pungulia, Ld. CIT (DR)
Section 143(3)Section 147Section 148Section 250

erred on facts as also in law in retaining addition of Rs.4,98,910/- by estimating profit at 16% of so called on money receipt. The addition made is bad in law as also on facts therefore the same may kindly be deleted. Alternatively, the addition made by estimating rate ... with Accounting principles as per 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. 503/RJT/2024

DCIT, Central Circle 1, Rajkot vs. Naresh Organisers Pvt. Ltd., Rajkot

ITA 516/RJT/2024[2020-21]Status: DisposedITAT Rajkot09 Mar 2026AY 2020-21

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinhaआयकर अपील सं/.Ita No.522 To 527/Rjt/2024 िनधा"रण वष"/ Assessment Year: (2017-2018 To 2022-23) बनाम Naresh Organisers Private Limited The Dcit, Cc-1 Rajkot Officer No. 702 R K Prime, 150 Feet Ring Vs. “Amruta Estate,” 2Nd Floor, Mg Road Next To Silver Heights, Nava Mava Road, Rajkot 360001, Gujrat Circle, Rajkot 360005, Gujrat /. /. Pan No. : Aaccn1282A "थायीलेखासं जीआइआरसं .. (अपीलाथ"/Appellant) (""यथ"/Respondent) आयकर अपील सं/.Ita No.503, 515 To 517/Rjt/2024 िनधा"रण वष"/ Assessment Year: (2018-19 To 2021-22) बनाम The Dcit, Cc-1 Rajkot Naresh Organisers Private Limited “Amruta Estate,” 2Nd Floor, Mg Vs. Officer No. 702 R K Prime, 150 Feet Road, Rajkot 360001, Gujrat Ring Road Next To Silver Heights, Nava Mava Circle, Rajkot 360005, Gujrat /. /. Pan No. : Aaccn1282A "थायीलेखासं जीआइआरसं .. (अपीलाथ"/Appellant) (""यथ"/Respondent)

For Appellant: Shri Mehul Ranapura, Ld. ARFor Respondent: Shri Sanjay Pungulia, Ld. CIT (DR)
Section 143(3)Section 147Section 148Section 250

erred on facts as also in law in retaining addition of Rs.4,98,910/- by estimating profit at 16% of so called on money receipt. The addition made is bad in law as also on facts therefore the same may kindly be deleted. Alternatively, the addition made by estimating rate ... with Accounting principles as per 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. 503/RJT/2024

DCIT, Central Circle 1, Rajkot vs. Naresh Orgnisers Pvt. Ltd., Rajkot

ITA 515/RJT/2024[2019-20]Status: DisposedITAT Rajkot09 Mar 2026AY 2019-20

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinhaआयकर अपील सं/.Ita No.522 To 527/Rjt/2024 िनधा"रण वष"/ Assessment Year: (2017-2018 To 2022-23) बनाम Naresh Organisers Private Limited The Dcit, Cc-1 Rajkot Officer No. 702 R K Prime, 150 Feet Ring Vs. “Amruta Estate,” 2Nd Floor, Mg Road Next To Silver Heights, Nava Mava Road, Rajkot 360001, Gujrat Circle, Rajkot 360005, Gujrat /. /. Pan No. : Aaccn1282A "थायीलेखासं जीआइआरसं .. (अपीलाथ"/Appellant) (""यथ"/Respondent) आयकर अपील सं/.Ita No.503, 515 To 517/Rjt/2024 िनधा"रण वष"/ Assessment Year: (2018-19 To 2021-22) बनाम The Dcit, Cc-1 Rajkot Naresh Organisers Private Limited “Amruta Estate,” 2Nd Floor, Mg Vs. Officer No. 702 R K Prime, 150 Feet Road, Rajkot 360001, Gujrat Ring Road Next To Silver Heights, Nava Mava Circle, Rajkot 360005, Gujrat /. /. Pan No. : Aaccn1282A "थायीलेखासं जीआइआरसं .. (अपीलाथ"/Appellant) (""यथ"/Respondent)

For Appellant: Shri Mehul Ranapura, Ld. ARFor Respondent: Shri Sanjay Pungulia, Ld. CIT (DR)
Section 143(3)Section 147Section 148Section 250

erred on facts as also in law in retaining addition of Rs.4,98,910/- by estimating profit at 16% of so called on money receipt. The addition made is bad in law as also on facts therefore the same may kindly be deleted. Alternatively, the addition made by estimating rate ... with Accounting principles as per 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. 503/RJT/2024

DCIT, Central Circle 1, Rajkot vs. Naresh Organisers Pvt. Ltd., Rjakot

ITA 503/RJT/2024[2018-19]Status: DisposedITAT Rajkot09 Mar 2026AY 2018-19

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinhaआयकर अपील सं/.Ita No.522 To 527/Rjt/2024 िनधा"रण वष"/ Assessment Year: (2017-2018 To 2022-23) बनाम Naresh Organisers Private Limited The Dcit, Cc-1 Rajkot Officer No. 702 R K Prime, 150 Feet Ring Vs. “Amruta Estate,” 2Nd Floor, Mg Road Next To Silver Heights, Nava Mava Road, Rajkot 360001, Gujrat Circle, Rajkot 360005, Gujrat /. /. Pan No. : Aaccn1282A "थायीलेखासं जीआइआरसं .. (अपीलाथ"/Appellant) (""यथ"/Respondent) आयकर अपील सं/.Ita No.503, 515 To 517/Rjt/2024 िनधा"रण वष"/ Assessment Year: (2018-19 To 2021-22) बनाम The Dcit, Cc-1 Rajkot Naresh Organisers Private Limited “Amruta Estate,” 2Nd Floor, Mg Vs. Officer No. 702 R K Prime, 150 Feet Road, Rajkot 360001, Gujrat Ring Road Next To Silver Heights, Nava Mava Circle, Rajkot 360005, Gujrat /. /. Pan No. : Aaccn1282A "थायीलेखासं जीआइआरसं .. (अपीलाथ"/Appellant) (""यथ"/Respondent)

For Appellant: Shri Mehul Ranapura, Ld. ARFor Respondent: Shri Sanjay Pungulia, Ld. CIT (DR)
Section 143(3)Section 147Section 148Section 250

erred on facts as also in law in retaining addition of Rs.4,98,910/- by estimating profit at 16% of so called on money receipt. The addition made is bad in law as also on facts therefore the same may kindly be deleted. Alternatively, the addition made by estimating rate ... with Accounting principles as per 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. 503/RJT/2024