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“undisclosed income”

Search & SeizureSection 153ASection 153A9,092 judgments

THE SIMALIYA DUDH UTPADAK SAHAKARI MANDLI LIMITED,PANCHMAHAL vs. THE ITO, WARD-1, GODHRA

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

ITA 2442/AHD/2025[2019-20]Status: DisposedITAT Ahmedabad09 Apr 2026AY 2019-20

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

For Appellant: Shri M K Patel, AdvocateFor Respondent: Smt. Ananya Kulshresth, Sr. DR
Section 147Section 234ASection 250(6)Section 270ASection 69C

facts in confirming the addition of Rs.26,17,000/- on account of cash withdrawals from the bank account treating the same as undisclosed income made by invoking the provisions of section 69C rws 115BBE of the I T Act, 1961, without The Simaliya Dudh Utpadak Sahakari Mandli

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

material on record. We find that it is an admitted fact that the assessee company, engaged in the real estate development business, has earned undisclosed income from on-money which the Special Auditor calculated at Rs 197.82 crore during the preceding period of six years from the date of search ... year of search. The ITAT (supra) accepted the said calculation and considered 20% of the gross receipt of on-money as undisclosed income as against the rate of 37.72% adopted by the authorities below. Page 9 of 19 ITA No. 3068/DEL/2022 Shalimar Corp [A.Y. 2017-18) 18. The issue

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

material on record. We find that it is an admitted fact that the assessee company, engaged in the real estate development business, has earned undisclosed income from on-money which the Special Auditor calculated at Rs 197.82 crore during the preceding period of six years from the date of search ... year of search. The ITAT (supra) accepted the said calculation and considered 20% of the gross receipt of on-money as undisclosed income as against the rate of 37.72% adopted by the authorities below. Page 9 of 19 ITA No. 3068/DEL/2022 Shalimar Corp [A.Y. 2017-18) 18. The issue

JAYESHKUMAR KAILASHCHANDRA BHADADA,AHMEDABAD vs. THE ITO, WARD-3(3)(5), AHMEDABAD

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

ITA 2318/AHD/2025[2018-19]Status: DisposedITAT Ahmedabad26 Mar 2026AY 2018-19

Bench: Shri Tr Senthil Kumar & Shri Narendra Prasad Sinhaassessment Years: 2018-19

Section 147Section 148Section 148A

total income of Rs.59,14,810/- wherein an addition of Rs. 51,22,000/- was made in respect of undisclosed income resulting out of bogus transaction carried out with M/s. Bright Corporation. 3. Aggrieved with the order of the AO, the assessee had filed an appeal before the first appellate ... dismissing the appeal of the appellant and confirmed the order of the assessing authority with regard to additions of Rs. 51,22,000/- towards undisclosed income as a result of bogus transactions with M/s. Bright Corporation. The action of the appellant authority and the AO for passing the ex-parte

DY. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, DEHRADUN, DEHRADUN vs. KOMA SINGHAL, DEHRADUN

In the result, appeal of the Revenue in ITA No

ITA 278/DDN/2025[2020-21]Status: DisposedITAT Dehradun25 Mar 2026AY 2020-21

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwal[Assessment Year : 2020-21] Dcit Vs Sandeep Sanghal Central Circle, 7, Ram Bagh, Near Anurag Dehradun Nursery, Kanwali Road, Uttarakhand Dehradun, Uttarakhand Pan-Aueps1161Q Appellant Respondent C.O.Nos.1 & 3/Ddn/2026 [In Ita No. 277/Ddn/2025] [Assessment Year : 2020-21] Sandeep Sanghal Vs Dcit 7, Ram Bagh, Near Anurag Central Circle, Nursery, Kanwali Road, Dehradun Dehradun, Uttarakhand Uttarakhand Pan-Aueps1161Q Appellant Respondent [Assessment Year : 2020-21] Dcit Vs Koma Singhal Central Circle, Village-Biasnehri, Haripur, Dehradun Kalsi Gate, Dehradun, Uttarakhand Uttarakhand-248001 Pan-Bnips9413F Appellant Respondent

Section 115BSection 132Section 143(2)Section 147Section 148Section 250Section 69B

noted as cash payment and accordingly, 50% of the share of assessee being INR 94,55,000/- was added as undisclosed income u/s 69B of the Act and provisions of section 115BBE of the Act were also invoked. 6. Against the said order, assessee filed an appeal before

DY. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, DEHRADUN, RAJPUR ROAD, DEHRADUN vs. SANDEEP SANGHAL, KANWLI ROAD, DEHRADUN

In the result, appeal of the Revenue in ITA No

ITA 277/DDN/2025[2020-21]Status: DisposedITAT Dehradun25 Mar 2026AY 2020-21

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwal[Assessment Year : 2020-21] Dcit Vs Sandeep Sanghal Central Circle, 7, Ram Bagh, Near Anurag Dehradun Nursery, Kanwali Road, Uttarakhand Dehradun, Uttarakhand Pan-Aueps1161Q Appellant Respondent C.O.Nos.1 & 3/Ddn/2026 [In Ita No. 277/Ddn/2025] [Assessment Year : 2020-21] Sandeep Sanghal Vs Dcit 7, Ram Bagh, Near Anurag Central Circle, Nursery, Kanwali Road, Dehradun Dehradun, Uttarakhand Uttarakhand Pan-Aueps1161Q Appellant Respondent [Assessment Year : 2020-21] Dcit Vs Koma Singhal Central Circle, Village-Biasnehri, Haripur, Dehradun Kalsi Gate, Dehradun, Uttarakhand Uttarakhand-248001 Pan-Bnips9413F Appellant Respondent

Section 115BSection 132Section 143(2)Section 147Section 148Section 250Section 69B

noted as cash payment and accordingly, 50% of the share of assessee being INR 94,55,000/- was added as undisclosed income u/s 69B of the Act and provisions of section 115BBE of the Act were also invoked. 6. Against the said order, assessee filed an appeal before

PRADEEP SHARDA,DEHRADUN vs. ACIT, DEHRADUN

In the result, the appeal of the assessee is allowed

ITA 223/DDN/2025[2017-18]Status: DisposedITAT Dehradun25 Mar 2026AY 2017-18

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwal[Assessment Year : 2017-18] Pradeep Sharda Vs Acit 7, Inder Road, Dehradun Circle-1(2)(1) Uttarakhand -248001 Dehradun Pan-Adwps5692K Uttarakhand Appellant Respondent Appellant By Shri Anil Jain, Adv. Respondent By Shri Amar Pal Singh, Sr.Dr Date Of Hearing 12.03.2026 Date Of Pronouncement 25.03.2026 Order Per Bench: The Present Appeal Is Filed By Assessee Against The Order Dated 24.09.2025 Passed By Ld. Commissioner Of Income Tax (A)/Addl/Jcit(A)-1, Nashik [“Ld. Cit(A)”] In Appeal No. Cit(A), Dehradun/10344/2019-20 U/S 250 Of The Income Tax Act, 1961 [“The Act”] Arising Out Of Assessment Order Dated 01.11.2019 Passed U/S 143(3) Of The Act Pertaining To Assessment Year 2017-18. 2. Brief Facts Of The Case Are That Assessee Is A Practicing Doctor & E-Filed His Return Of Income, Declaring Total Income Of Inr 2,16,70,906/- On 30.10.2017. The Assessment Was Completed U/S 143(3) Of The Act By Making Additions Of Inr 15,84,870/- Comprising Of The Disallowance U/S 40(A)(Ia) Of The Act Of Inr 5,05,195/- & Treating The Agricultural Income Of Inr 6,25,000/- As Unexplained Money U/S 69A Of The Act & Of Inr 4,54,675/- As The Addition U/S 68 Of The Act On Account Of Cash Credit.

Section 143(3)Section 250Section 40Section 68Section 69A

made u/s 68 of the Act and confirmed the addition of INR 6,25,000/- made on account of agricultural income treated as undisclosed income and disallowance made u/s 40(a)(ia) of the Act of INR 5,05,195/-. 4. Before us, in respect of Ground of appeal No.2 ... declared less, this alone could not be made basis for holding the agricultural income received during the year from sale of apples as undisclosed income without bringing any corroborative material on record. 11. In the light of above facts where the agricultural income declared by the assessee is duly backed

VIDYA SHANKER JAISWAL, SARGUJA,SARGUJA vs. ITO, WARD-2, AMBIKAPUR, AMBIKAPUR

The appeals of the assessee are allowed

ITA 142/RPR/2026[2014-15]Status: DisposedITAT Raipur24 Mar 2026AY 2014-15

Bench: Shri Partha Sarathi Chaudhuryआयकर अपील सं./Ita Nos.141 & 142/Rpr/2026 "नधा"रण वष" /Assessment Years : 2013-14 & 2014-15

For Appellant: S/shri Yash Dhariwal &For Respondent: Dr. Priyanka Patel, Sr. DR
Section 143Section 143(2)Section 143(3)Section 148

assessments, makes such notice the very foundation for jurisdiction. Such notice is required to be served on the person who is found to have undisclosed income. Section 158BC provides for enquiry and assessment. After the return is filed, clause (b) of section 158BC provides that the Assessing Officer shall proceed ... determine the undisclosed income of the block period in the manner laid down in section 158BB and "the provisions of section 142, sub-sections (2) and (3) of section 143, section 144 and section 145 shall, so far as may be, apply". This indicates that this clause enables the Assessing

VIDYA SHANKER JAISWAL, SARGUJA,SARGUJA vs. ITO, WARD-2, AMBIKAPUR, AMBIKAPUR

The appeals of the assessee are allowed

ITA 141/RPR/2026[2013-14]Status: DisposedITAT Raipur24 Mar 2026AY 2013-14

Bench: Shri Partha Sarathi Chaudhuryआयकर अपील सं./Ita Nos.141 & 142/Rpr/2026 "नधा"रण वष" /Assessment Years : 2013-14 & 2014-15

For Appellant: S/shri Yash Dhariwal &For Respondent: Dr. Priyanka Patel, Sr. DR
Section 143Section 143(2)Section 143(3)Section 148

assessments, makes such notice the very foundation for jurisdiction. Such notice is required to be served on the person who is found to have undisclosed income. Section 158BC provides for enquiry and assessment. After the return is filed, clause (b) of section 158BC provides that the Assessing Officer shall proceed ... determine the undisclosed income of the block period in the manner laid down in section 158BB and "the provisions of section 142, sub-sections (2) and (3) of section 143, section 144 and section 145 shall, so far as may be, apply". This indicates that this clause enables the Assessing

ASSTT. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-4, , JAIPUR vs. GOPAL PRASAD GUPTA, JAIPUR

The appeals of the revenue are dismissed

ITA 1765/JPR/2025[2013-14]Status: DisposedITAT Jaipur23 Mar 2026AY 2013-14

Bench: Shri Sanjay Garg & Shri Ratnesh Nandan Sahay

For Appellant: Sh. Rajnikant Bhatra, CAFor Respondent: Sh. Rajesh Ojha, CIT
Section 147Section 148Section 153CSection 250

matter is that under Section 153A and 153C, ‘the total income’ is to be assessed. The total income includes returned income (if any), undisclosed income unearthed during the search or requisitioning and information possessed from the other sources. For Illustration:- An assessee had returned income of Rs.100, undisclosed income ... 153C shall pass order dealing with income of Rs.100+Rs.200+Rs.150, the total income being Rs.450/-. In cases where there is no unearthing of undisclosed income of Rs.200/-, the department can resort to proceeding under Section 147/148. 32. The argument that Section 153C can be invoked in case there

ASSTT. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-4, JAIPUR vs. GOPAL PRASAD GUPTA, JAIPUR

The appeals of the revenue are dismissed

ITA 1764/JPR/2025[2016-17]Status: DisposedITAT Jaipur23 Mar 2026AY 2016-17

Bench: Shri Sanjay Garg & Shri Ratnesh Nandan Sahay

For Appellant: Sh. Rajnikant Bhatra, CAFor Respondent: Sh. Rajesh Ojha, CIT
Section 147Section 148Section 153CSection 250

matter is that under Section 153A and 153C, ‘the total income’ is to be assessed. The total income includes returned income (if any), undisclosed income unearthed during the search or requisitioning and information possessed from the other sources. For Illustration:- An assessee had returned income of Rs.100, undisclosed income ... 153C shall pass order dealing with income of Rs.100+Rs.200+Rs.150, the total income being Rs.450/-. In cases where there is no unearthing of undisclosed income of Rs.200/-, the department can resort to proceeding under Section 147/148. 32. The argument that Section 153C can be invoked in case there

RAJESH KUMAR TIWARI, RAIPUR,RAIPUR vs. INCOME TAX OFFICER, WARD-2(2), RAIPUR, RAIPUR

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

ITA 844/RPR/2025[2012-13]Status: DisposedITAT Raipur20 Mar 2026AY 2012-13

Bench: Shri Partha Sarathi Chaudhury, Jm & Shri Avdhesh Kumar Mishra, Am आयकर अपील सं. / Ita No: 844/Rpr/2025 (िनधा"रण वष" Assessment Year: 2012-13) Rajesh Kumar Tiwari, Shiv Mandir Gali, Vs Income Tax Officer, Ward-2(2), Gali No.9, Basant Vihar, Gondwara, Raipur, Income Tax Office, Raipur, Chhattisgarh-493221 Central Revenue Building, Civil Lines, Raipur, C.G. - 492001 Pan: Ajgpt8095F (अपीलाथ"/Appellant) (""थ" / Respondent) : िनधा"रती की ओर से / Assessee By : None (Adjournment Filed) राज" की ओर से / Revenue By : Dr. Priyanka Patel, Sr. Dr सुनवाई की तारीख / Date Of Hearing : 17/03/2026 घोषणा की तारीख / Date Of : 20/03/2026 Pronouncement

For Appellant: None (Adjournment filed)For Respondent: Dr. Priyanka Patel, Sr. DR
Section 131Section 151Section 250Section 69A

final show cause notice during assessment proceeding, has erred in stating that -"you are required to show cause as to why should the undisclosed income from business for Rs. 7,25,322/- and credit entry of Rs. Rs. 74,76,720/-from M/s Hind Energy and Coal Benefication

DEPUTY COMMISSIONER OF INCOME TAX, DELHI vs. M/S VESTIGE MARKETING PRIVATE LIMITED, DELHI

ITA 7844/DEL/2025[2024-25]Status: DisposedITAT Delhi20 Mar 2026AY 2024-25
Section 132Section 133(6)Section 143(3)Section 147Section 37Section 37(1)Section 69A

made a categorical admission that\nthe said sum of Rs.86 lakhs belonged to him; -- that the seized\ncash amount of Rs.86 lakhs represented “my undisclosed income\nnot recorded in the Books of Accounts”.\n6. The Assessee retracted the above admission during the\ncourse of the assessment proceedings, but not immediately ... there should be focus and concentration on\ncollection of evidence of income and no attempt should be made to\nobtain confession as to the undisclosed income. Thus, CBDT has itself\nrecognized the position that assessment of undisclosed income has\nbeen based upon evidence and not on statement.\n1.3 In this

DEPUTY COMMISSIONER OF INCOME TAX, DELHI vs. M/S VESTIGE MARKETING PRIVATE LIMITED, DELHI

ITA 7843/DEL/2025[2023-24]Status: DisposedITAT Delhi20 Mar 2026AY 2023-24
Section 132Section 133(6)Section 143(3)Section 147Section 37Section 37(1)Section 69A

made a categorical admission that\nthe said sum of Rs.86 lakhs belonged to him; -- that the seized\ncash amount of Rs.86 lakhs represented “my undisclosed income\nnot recorded in the Books of Accounts”.\n6. The Assessee retracted the above admission during the\ncourse of the assessment proceedings, but not immediately ... there should be focus and concentration on\ncollection of evidence of income and no attempt should be made to\nobtain confession as to the undisclosed income. Thus, CBDT has itself\nrecognized the position that assessment of undisclosed income has\nbeen based upon evidence and not on statement.\n1.3 In this

DEPUTY COMMISSIONER OF INCOME TAX, DELHI vs. M/S VESTIGE MARKETING PRIVATE LIMITED, DELHI

ITA 7842/DEL/2025[2022-23]Status: DisposedITAT Delhi20 Mar 2026AY 2022-23

Bench: Shri Before Shri Satbeer Singh Godarabefore Shri Before Shri Satbeer Singh Godarasatbeer Singh Godara & Satbeer Singh Godara & And & Shri Naveen Chandra Shri Naveen Chandra, , , Shri Naveen Chandra Shri Naveen Chandra

For Appellant: Shri Amit Goel and Shri Pranav Yadav, Advocate
Section 132Section 143(3)Section 147Section 37Section 37(1)Section 69A

made a categorical admission that the said sum of Rs.86 lakhs belonged to him; ---- that the seized cash amount of Rs.86 lakhs represented “my undisclosed income not recorded in the Books of Accounts”. 6. The Assessee retracted the above admission during the course of the assessment proceedings, but not immediately ... there should be focus and concentration on collection of evidence of income and no attempt should be made to obtain confession as to the undisclosed income. Thus, CBDT has itself recognized the position that assessment of undisclosed income has been based upon evidence and not on statement. 1.3 In this

DEPUTY COMMISSIONER OF INCOME TAX, DELHI vs. M/S VESTIGE MARKETING PRIVATE LIMITED, DELHI

ITA 7841/DEL/2025[2021-22]Status: DisposedITAT Delhi20 Mar 2026AY 2021-22
Section 132Section 133(6)Section 143(3)Section 147Section 37Section 37(1)Section 69A

made a categorical admission that\nthe said sum of Rs.86 lakhs belonged to him; -- that the seized\ncash amount of Rs.86 lakhs represented “my undisclosed income\nnot recorded in the Books of Accounts”.\n6. The Assessee retracted the above admission during the\ncourse of the assessment proceedings, but not immediately ... there should be focus and concentration on\ncollection of evidence of income and no attempt should be made to\nobtain confession as to the undisclosed income. Thus, CBDT has itself\nrecognized the position that assessment of undisclosed income has\nbeen based upon evidence and not on statement.\n1.3 In this

DEPUTY COMMISSIONER OF INCOME TAX, DELHI vs. M/S VESTIGE MARKETING PRIVATE LIMITED, DELHI

ITA 7840/DEL/2025[2020-21]Status: DisposedITAT Delhi20 Mar 2026AY 2020-21

Bench: Shri Before Shri Satbeer Singh Godarabefore Shri Before Shri Satbeer Singh Godarasatbeer Singh Godara & Satbeer Singh Godara & And & Shri Naveen Chandra Shri Naveen Chandra, , , Shri Naveen Chandra Shri Naveen Chandra

For Appellant: Shri Amit Goel and Shri Pranav Yadav, Advocate
Section 132Section 143(3)Section 147Section 37Section 37(1)Section 69A

made a categorical admission that the said sum of Rs.86 lakhs belonged to him; ---- that the seized cash amount of Rs.86 lakhs represented “my undisclosed income not recorded in the Books of Accounts”. 6. The Assessee retracted the above admission during the course of the assessment proceedings, but not immediately ... there should be focus and concentration on collection of evidence of income and no attempt should be made to obtain confession as to the undisclosed income. Thus, CBDT has itself recognized the position that assessment of undisclosed income has been based upon evidence and not on statement. 1.3 In this

DEPUTY COMMISSIONER OF INCOME TAX, DELHI vs. M/S VESTIGE MARKETING PRIVATE LIMITED, DELHI

ITA 7839/DEL/2025[2019-20]Status: DisposedITAT Delhi20 Mar 2026AY 2019-20
Section 132Section 133(6)Section 143(3)Section 147Section 37Section 37(1)Section 69A

made a categorical admission that\nthe said sum of Rs.86 lakhs belonged to him; -- that the seized\ncash amount of Rs.86 lakhs represented “my undisclosed income\nnot recorded in the Books of Accounts”.\n6. The Assessee retracted the above admission during the\ncourse of the assessment proceedings, but not immediately ... there should be focus and concentration on\ncollection of evidence of income and no attempt should be made to\nobtain confession as to the undisclosed income. Thus, CBDT has itself\nrecognized the position that assessment of undisclosed income has\nbeen based upon evidence and not on statement.\n1.3 In this

DEPUTY COMMISSIONER OF INCOME TAX, DELHI vs. M/S VESTIGE MARKETING PRIVATE LIMITED, DELHI

ITA 7838/DEL/2025[2018-19]Status: DisposedITAT Delhi20 Mar 2026AY 2018-19
For Appellant: Shri Amit Goel andFor Respondent: Ms. Monika Singh, CIT-DR
Section 132Section 133(6)Section 143(3)Section 147Section 37Section 37(1)Section 69A

made a categorical admission that\nthe said sum of Rs.86 lakhs belonged to him; -- that the seized\ncash amount of Rs.86 lakhs represented “my undisclosed income\nnot recorded in the Books of Accounts”.\n6. The Assessee retracted the above admission during the\ncourse of the assessment proceedings, but not immediately ... there should be focus and concentration on\ncollection of evidence of income and no attempt should be made to\nobtain confession as to the undisclosed income. Thus, CBDT has itself\nrecognized the position that assessment of undisclosed income has\nbeen based upon evidence and not on statement.\n1.3 In this

VIKAS AGARWAL,BULANDSHAHR vs. ACIT, CENTRAL CIRCLE, MEERUT

In the result, all the appeals of the assessee are allowed

ITA 6485/DEL/2025[2016-17]Status: DisposedITAT Delhi20 Mar 2026AY 2016-17

Bench: Ms. Madhumita Roy & Shri Amitabh Shukla, Accountnat Member

Section 153ASection 69

supported by some enquiries by the Revenue authorities so as to fasten the ownership of the document with the assessee in whose case undisclosed income is to be assessed. In the present case, the same were missing. Accordingly, we are of the considered opinion that no case of any addition

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