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“undisclosed income”

Search & SeizureSection 153ASection 153A9,092 judgments

The decision most relied on for undisclosed income is CIT v. Kabul Chawla (380 ITR 573), cited in 3,235 judgments on BharatTax.

Leading authorities on undisclosed income

CIT v. Kabul Chawla
380 ITR 573 · 2016 · High Court
3,235
citing judgments

In a search assessment under Section 153A, additions can only be made for completed or non-abated assessment years if incriminating material relevant to those years is found during the search, although notice under Section 153A(1) is mandatorily issued for six assessment years preceding the search.

CIT v. Simit P. Sheth
356 ITR 451 · 2013 · High Court
1,465
citing judgments

Additions for alleged bogus purchases should be restricted to the profit element, not the entire turnover. The profit element is often estimated at 12.5% of the purported bogus purchases.

Commissioner of Income Tax v. Harjeev Aggarwal
290 CTR 263 · 2016 · High Court
583
citing judgments

Assessment based solely on a statement recorded under Section 132(4) of the Income Tax Act requires the statement to be relatable to incriminating material or evidence found during the search, especially when considering Section 158BB(1) which restricts computation of undisclosed income to evidence found during search.

CIT v. Anil Kumar Bhatia
352 ITR 493 · 2013 · High Court
537
citing judgments

Section 153A can be invoked to reassess income for all years under consideration prior to a search, even if returns for those years were processed under Section 143(1)(a). The Assessing Officer has the power to reassess total income in such cases without fetters.

CIT v. P. Mohanakala
291 ITR 278 · 2007 · Supreme Court
525
citing judgments

The Supreme Court emphasized that in the absence of concrete rebuttal by the assessee, circumstantial evidence holds significant weight, applying the doctrine of preponderance of probability, particularly when assessing undisclosed income or unexplained cash credits.

Society v. UOI
394 ITR 220 · 2017 · Supreme Court
493
citing judgments

Uncorroborated loose papers or documents found during a search operation have no evidentiary value and cannot be the sole basis for determining undisclosed income. Additions based on such material require independent evidence to establish trustworthiness and a direct link to the assessee.

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.

CIT v. Gurinder Singh Bawa
386 ITR 483 · 2016 · High Court
416
citing judgments

If no incriminating material is found during a search operation regarding a particular issue, then no addition can be made concerning that issue in an assessment under section 153A of the Income-tax Act.

Judgments citing undisclosed income

Mahadhan Agritech Limited (Formerly Known As Smartchem Technologies Limited ), Mumbai vs. Deputy Commissioner of Income Tax, Central Circle -8(1), Mumbai

In the result, the appeals filed by the assessee are allowed, and the appeal filed by the Revenue is dismissed

ITA 3937/MUM/2024[2019-20]Status: DisposedITAT Mumbai24 Jul 2025AY 2019-20

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)

Section 115JSection 132Section 143(3)Section 153ASection 69A

considering the cardinal principle of law that the scope of assessment u/s 153A in respect of completed / unabated assessment is limited only to undisclosed income unearthed during the course of search. Ground 1(c) - That on the facts and in the circumstances of the case, the Ld. CIT(Appeals ... facts and in the circumstances of the case, the Ld. CIT(Appeals) was not justified and grossly erred in confirming the additions of undisclosed income us 69A on account of alleged inflated capital expenditure while Act. Ground 4 - That on the facts and in the circumstances of the case

DCIT Central Circle 8(1), Mumbai vs. Mahadhan Agritech Limited, Pune

In the result, the appeals filed by the assessee are allowed, and the appeal filed by the Revenue is dismissed

ITA 3569/MUM/2024[2019-20]Status: DisposedITAT Mumbai24 Jul 2025AY 2019-20

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)

Section 115JSection 132Section 143(3)Section 153ASection 69A

considering the cardinal principle of law that the scope of assessment u/s 153A in respect of completed / unabated assessment is limited only to undisclosed income unearthed during the course of search. Ground 1(c) - That on the facts and in the circumstances of the case, the Ld. CIT(Appeals ... facts and in the circumstances of the case, the Ld. CIT(Appeals) was not justified and grossly erred in confirming the additions of undisclosed income us 69A on account of alleged inflated capital expenditure while Act. Ground 4 - That on the facts and in the circumstances of the case

Mahadhan Agritech Limited (Formerly Known As Smartchem Technologies Ltd, Mumbai vs. Commissioner of Income Tax(Appeal)--50, Mumai

In the result, the appeals filed by the assessee are allowed, and the appeal filed by the Revenue is dismissed

ITA 2229/MUM/2024[2018-19]Status: DisposedITAT Mumbai24 Jul 2025AY 2018-19

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)

Section 115JSection 132Section 143(3)Section 153ASection 69A

considering the cardinal principle of law that the scope of assessment u/s 153A in respect of completed / unabated assessment is limited only to undisclosed income unearthed during the course of search. Ground 1(c) - That on the facts and in the circumstances of the case, the Ld. CIT(Appeals ... facts and in the circumstances of the case, the Ld. CIT(Appeals) was not justified and grossly erred in confirming the additions of undisclosed income us 69A on account of alleged inflated capital expenditure while Act. Ground 4 - That on the facts and in the circumstances of the case

Mahadhan Agritech Limited (Formerly Knwon As Smartech Technologies Ltd ), Mumbai vs. Commissioner of Income Tax (Appeals)-Mumbai-50, Mumbai

In the result, the appeals filed by the assessee are

ITA 2228/MUM/2024[2016-17]Status: DisposedITAT Mumbai24 Jul 2025AY 2016-17
Section 115JSection 132Section 143(3)Section 153ASection 69A

considering the cardinal principle of law that the scope of assessment u/s 153A in respect of completed / unabated assessment is limited only to undisclosed income unearthed during the course of search. Ground 1(c) - That on the facts and in the circumstances of the case, the Ld. CIT(Appeals ... facts and in the circumstances of the case, the Ld. CIT(Appeals) was not justified and grossly erred in confirming the additions of undisclosed income us 69A on account of alleged inflated capital expenditure while ITA No.2227/Mum/2024 and others Mahadhan Agritech Limited 4 computing total income under the normal provisions

Mahadhan Agritech Limited (Formerly Known As Smartech Technologies Ltd, Mumbai vs. Commissioner of Income Tax (Appeals)-Mumbai.50, Mumbai

In the result, the appeals filed by the assessee are allowed, and the appeal filed by the Revenue is dismissed

ITA 2227/MUM/2024[2017-18]Status: DisposedITAT Mumbai24 Jul 2025AY 2017-18

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)

Section 115JSection 132Section 143(3)Section 153ASection 69A

considering the cardinal principle of law that the scope of assessment u/s 153A in respect of completed / unabated assessment is limited only to undisclosed income unearthed during the course of search. Ground 1(c) - That on the facts and in the circumstances of the case, the Ld. CIT(Appeals ... facts and in the circumstances of the case, the Ld. CIT(Appeals) was not justified and grossly erred in confirming the additions of undisclosed income us 69A on account of alleged inflated capital expenditure while Act. Ground 4 - That on the facts and in the circumstances of the case

Income Tax Officer-42(2)(3), Kautilya Bhavan, Bkc vs. Kaushik Balubhai Madhwani, Girgaon, Mumbai

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

ITA 2861/MUM/2023[2014-15]Status: DisposedITAT Mumbai24 Jul 2025AY 2014-15

Bench: Shri Amit Shukla & Shri Girish Agrawalassessment Year: 2014-15

For Appellant: Shri Sharwan Kumar Jha, AdvFor Respondent: Shri RiteshMisra, CIT DR
Section 10(38)Section 132(4)Section 143(3)Section 68

right in deleting the addition of Rs. 29,43, 664/- without appreciating the fact that the addition was made on account of undisclosed income on the basis of the statement recorded u/s. 132(4) of the accommodation entry provider, which is evidence as per section 132(4) of the Income

Professional Automotives Private Limited, Jammu vs. Assistant Commissioner of Income Tax, Jaipur

In the result the appeal of the assessee in ITA no

ITA 815/JPR/2025[2019-20]Status: DisposedITAT Jaipur23 Jul 2025AY 2019-20
For Appellant: Shri Tarun Mittal, CAFor Respondent: Shri Ajey Malik, CIT (Th. V.C)
Section 143(3)Section 37(1)

Rs.2,39,48,071/-, may be explained along with documentary evidences. Also show-cause as to why these expenses should not be treated as Undisclosed Income for the year under consideration." 6.5 The assessee has submitted his detailed reply/submission on 21.04.2021. In that the assessee contended that the proposal ... admitted fact that the Managing Partner of the firms in question has given a voluntary statement to the Assessing Officer that there is a undisclosed income of Rs.2.75 Crores, which according to he learned counsel, was retracted by the Managing Partner subsequently. Thusit can be seen that even according

Professional Automotives Private Limited, Jammu vs. Assisstant Commissioner of Income Tax Central Circle-1, Jaipur

In the result the appeal of the assessee in ITA no

ITA 814/JPR/2025[2018-19]Status: DisposedITAT Jaipur23 Jul 2025AY 2018-19
For Appellant: Shri Tarun Mittal, CAFor Respondent: Shri Ajey Malik, CIT (Th. V.C)
Section 143(3)Section 37(1)

Rs.2,39,48,071/-, may be explained along with documentary evidences. Also show-cause as to why these expenses should not be treated as Undisclosed Income for the year under consideration." 6.5 The assessee has submitted his detailed reply/submission on 21.04.2021. In that the assessee contended that the proposal ... admitted fact that the Managing Partner of the firms in question has given a voluntary statement to the Assessing Officer that there is a undisclosed income of Rs.2.75 Crores, which according to he learned counsel, was retracted by the Managing Partner subsequently. Thusit can be seen that even according

Professional Automotives Private Limited, Jammu vs. Assistant Commissioner of Income Tax, Central Circle-1, Jaipur

ITA 813/JPR/2025[2017-18]Status: DisposedITAT Jaipur23 Jul 2025AY 2017-18
For Appellant: Shri Tarun Mittal, CAFor Respondent: Shri Ajey Malik, CIT (Th. V.C)
Section 132(4)Section 143(3)Section 37(1)

Rs.2,39,48,071/-, may be explained along with documentary evidences. Also show-cause as to why these expenses should not be treated as Undisclosed Income for the year under consideration." 6.5 The assessee has submitted his detailed reply/submission on 21.04.2021. In that the assessee contended that the proposal ... para of the judgement is as under 5. (e) We have considered the rival submissions. The appellant sought to rely upon the definition of undisclosed income which has been defined in Section 1588(b) of the Act. Undisclosed income is defined as any income based on any entry

Professional Automotives Private Limited, Jammu vs. Assistant Commissioner of Income Tax, Central Circle-1, Jaipur

In the result the appeal of the assessee in ITA no

ITA 812/JPR/2025[2016-17]Status: DisposedITAT Jaipur23 Jul 2025AY 2016-17

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI, आयकर अपील /ITA Nos.809 to 815/JP/2025 निर्धारण वर्ष /Assessment Years :2013-14 to 2019-20 Professional Automotives Pvt. बनाम ACIT, Ltd. Bahu Plaza, Bahu Plaza, Jammu Vs. Central Circle- 1, and Kashmir Jaipur स्थायी लेखा सं./जी.आई.आर. सं./PAN/GIR No.:AAACP9608E अपीलार्थी/Appellant प्र]त्यर्थी/Respondent निर्धारिती की ओर से / Assessee by :Shri Tarun Mittal, CA राजस्व की ओर से /Revenue by: Shri Ajey Malik, CIT (Th. V.C)

For Appellant: Shri Tarun Mittal, CAFor Respondent: Shri Ajey Malik, CIT (Th. V.C)
Section 143(3)Section 37(1)

Rs.2,39,48,071/-, may be explained along with documentary evidences. Also show-cause as to why these expenses should not be treated as Undisclosed Income for the year under consideration." 6.5 The assessee has submitted his detailed reply/submission on 21.04.2021. In that the assessee contended that the proposal ... admitted fact that the Managing Partner of the firms in question has given a voluntary statement to the Assessing Officer that there is a undisclosed income of Rs.2.75 Crores, which according to the learned counsel, was retracted by the Managing Partner subsequently. Thusit can be seen that even according

Professional Automotives Private Limited, Jammu vs. Assisstant Commissioner of Income Tax, Central Circle-1, Jaipur

In the result the appeal of the assessee in ITA no

ITA 811/JPR/2025[2015-16]Status: DisposedITAT Jaipur23 Jul 2025AY 2015-16
For Appellant: Shri Tarun Mittal, CAFor Respondent: Shri Ajey Malik, CIT (Th. V.C)
Section 143(3)Section 37(1)

Rs.2,39,48,071/-, may be explained along with documentary evidences. Also show-cause as to why these expenses should not be treated as Undisclosed Income for the year under consideration." 6.5 The assessee has submitted his detailed reply/submission on 21.04.2021. In that the assessee contended that the proposal ... admitted fact that the Managing Partner of the firms in question has given a voluntary statement to the Assessing Officer that there is a undisclosed income of Rs.2.75 Crores, which according to he learned counsel, was retracted by the Managing Partner subsequently. Thusit can be seen that even according

Professional Automotives Private Limited, Jammu vs. Assistant Commissioner of Income Tax, Centre Circle -1, Jaipur

ITA 810/JPR/2025[2014-15]Status: DisposedITAT Jaipur23 Jul 2025AY 2014-15
For Appellant: Shri Tarun Mittal, CAFor Respondent: Shri Ajey Malik, CIT (Th. V.C)
Section 143(3)Section 37(1)

Rs.2,39,48,071/-, may be explained along with documentary evidences. Also show-cause as to why these expenses should not be treated as Undisclosed Income for the year under consideration." 6.5 The assessee has submitted his detailed reply/submission on 21.04.2021. In that the assessee contended that the proposal ... other words, there will be only one assessment order in respect of each of the six AYs "in which both the disclosed and the undisclosed income would be brought to tax". iv. Although Section 153 A does not say that additions should be strictly made on the basis of evidence

Professional Automotives Private Limited, Jammu vs. Assistant Commissioner of Income Tax, Central Circle -1, Jaipur

ITA 809/JPR/2025[2013-14]Status: DisposedITAT Jaipur23 Jul 2025AY 2013-14
For Appellant: Shri Tarun Mittal, CAFor Respondent: Shri Ajey Malik, CIT (Th. V.C)
Section 143(3)Section 37(1)

Rs.2,39,48,071/-, may be explained along with documentary evidences. Also show-cause as to why these expenses should not be treated as Undisclosed Income for the year under consideration." 6.5 The assessee has submitted his detailed reply/submission on 21.04.2021. In that the assessee contended that the proposal ... admitted fact that the Managing Partner of the firms in question has given a voluntary statement to the Assessing Officer that there is a undisclosed income of Rs.2.75 Crores, which according to the learned counsel, was retracted by the Managing Partner subsequently. Thusit can be seen that even according

M/S Banna Lal Jat Constructions Pvt. Ltd., Bhilwara vs. DCIT, Central Circle, Ajmer

Appeal is partly allowed by reducing the penalty to the

ITA 1569/JPR/2024[2015-16]Status: DisposedITAT Jaipur23 Jul 2025AY 2015-16

Bench: SHRI GAGAN GOYAL (Accountant Member), SHRI NARINDER KUMAR (Judicial Member)

For Appellant: Shri P.C. Parwal, C.AFor Respondent: Mrs. Anita Rinesh, JCIT, Sr. DR
Section 132Section 250Section 271ASection 274

penalty, in addition to tax, if any, payable by him,— (a) a sum computed at the rate of ten per cent of the undisclosed income of the specified previous year, if such assessee— (i) in the course of the search, in a statement under sub-section (4) of section ... admits the undisclosed income and specifies the manner in which such income has been derived; (ii) substantiates the manner in which the undisclosed income was derived; and (iii) on or before the specified date— (A) pays the tax, together with interest, if any, in respect of the undisclosed income

Paradigm Business Ventures, Mohali vs. Deputy Commissioner of Income Tax, Central Circle-1, Chandigarh

The appeals stand allowed in terms of our above order

ITA 1139/CHANDI/2024[2016-17]Status: DisposedITAT Chandigarh23 Jul 2025AY 2016-17

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am 1. आयकर अपील सं./ Ita No.1128/Chandi/2024 (िनधा"रण वष" / Assessment Year: 2017-18) 2. आयकर अपील सं./ Ita No.1129/Chandi/2024 (िनधा"रण वष" / Assessment Year: 2017-18) 3. आयकर अपील सं./ Ita No.1139/Chandi/2024 (िनधा"रण वष" / Assessment Year: 2016-17) M/S Paradigm Business Ventures Dcit-Circle 1 बनाम/ Vs. Sco 45 Hollywood Plaza Cr Building Vip Road Zirakpur Mohali. Chandigarh "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aaqfp-5590-G (अपीलाथ"/Appellant) : (""थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Shri Parikshit Aggarwal(Ca) – Ld. Ar ""थ"कीओरसे/Respondent By : Smt. Kusum Bansal (Cit, Virtual) – Ld. Dr & Dr. Ranjit Kaur (Addl. Cit) – Ld. Sr. Dr सुनवाईक"तार"ख/Date Of Hearing : 15-07-2025 घोषणाक"तार"ख /Date Of Pronouncement : 23-07-2025 आदेश / O R D E R Manoj Kumar Aggarwal ()

For Appellant: Shri Parikshit Aggarwal(CA) – Ld. ARFor Respondent: Smt. Kusum Bansal (CIT, Virtual) – Ld. DR & Dr
Section 115BSection 143(3)Section 271A

added u/s 68 to 69D. The addition is purely on the basis of undertaking given by the assessee. In our opinion, existence of undisclosed income is sine qua non to invoke the impugned penalty provisions. The undisclosed income is to be represented by any money, bullion, jewellery or other valuable

Paradigm Business Ventures, Mohali vs. Deputy Commisioner of Income Tax, CC-1, Chandigarh

The appeals stand allowed in terms of our above order

ITA 1129/CHANDI/2024[2017-18]Status: DisposedITAT Chandigarh23 Jul 2025AY 2017-18

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am 1. आयकर अपील सं./ Ita No.1128/Chandi/2024 (िनधा"रण वष" / Assessment Year: 2017-18) 2. आयकर अपील सं./ Ita No.1129/Chandi/2024 (िनधा"रण वष" / Assessment Year: 2017-18) 3. आयकर अपील सं./ Ita No.1139/Chandi/2024 (िनधा"रण वष" / Assessment Year: 2016-17) M/S Paradigm Business Ventures Dcit-Circle 1 बनाम/ Vs. Sco 45 Hollywood Plaza Cr Building Vip Road Zirakpur Mohali. Chandigarh "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aaqfp-5590-G (अपीलाथ"/Appellant) : (""थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Shri Parikshit Aggarwal(Ca) – Ld. Ar ""थ"कीओरसे/Respondent By : Smt. Kusum Bansal (Cit, Virtual) – Ld. Dr & Dr. Ranjit Kaur (Addl. Cit) – Ld. Sr. Dr सुनवाईक"तार"ख/Date Of Hearing : 15-07-2025 घोषणाक"तार"ख /Date Of Pronouncement : 23-07-2025 आदेश / O R D E R Manoj Kumar Aggarwal ()

For Appellant: Shri Parikshit Aggarwal(CA) – Ld. ARFor Respondent: Smt. Kusum Bansal (CIT, Virtual) – Ld. DR & Dr
Section 115BSection 143(3)Section 271A

added u/s 68 to 69D. The addition is purely on the basis of undertaking given by the assessee. In our opinion, existence of undisclosed income is sine qua non to invoke the impugned penalty provisions. The undisclosed income is to be represented by any money, bullion, jewellery or other valuable

Paradigm Business Ventures, Mohali vs. Deputy Commissioner of Income Tax, CC-1, Chandigarh

The appeals stand allowed in terms of our above order

ITA 1128/CHANDI/2024[2017-18]Status: DisposedITAT Chandigarh23 Jul 2025AY 2017-18

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am 1. आयकर अपील सं./ Ita No.1128/Chandi/2024 (िनधा"रण वष" / Assessment Year: 2017-18) 2. आयकर अपील सं./ Ita No.1129/Chandi/2024 (िनधा"रण वष" / Assessment Year: 2017-18) 3. आयकर अपील सं./ Ita No.1139/Chandi/2024 (िनधा"रण वष" / Assessment Year: 2016-17) M/S Paradigm Business Ventures Dcit-Circle 1 बनाम/ Vs. Sco 45 Hollywood Plaza Cr Building Vip Road Zirakpur Mohali. Chandigarh "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aaqfp-5590-G (अपीलाथ"/Appellant) : (""थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Shri Parikshit Aggarwal(Ca) – Ld. Ar ""थ"कीओरसे/Respondent By : Smt. Kusum Bansal (Cit, Virtual) – Ld. Dr & Dr. Ranjit Kaur (Addl. Cit) – Ld. Sr. Dr सुनवाईक"तार"ख/Date Of Hearing : 15-07-2025 घोषणाक"तार"ख /Date Of Pronouncement : 23-07-2025 आदेश / O R D E R Manoj Kumar Aggarwal ()

For Appellant: Shri Parikshit Aggarwal(CA) – Ld. ARFor Respondent: Smt. Kusum Bansal (CIT, Virtual) – Ld. DR & Dr
Section 115BSection 143(3)Section 271A

added u/s 68 to 69D. The addition is purely on the basis of undertaking given by the assessee. In our opinion, existence of undisclosed income is sine qua non to invoke the impugned penalty provisions. The undisclosed income is to be represented by any money, bullion, jewellery or other valuable

Shri Satish Soin, Ludhiana vs. ACIT, CC-II, Ludhiana

In the result, appeal of the assessee is allowed

ITA 303/CHANDI/2019[2012-13]Status: DisposedITAT Chandigarh23 Jul 2025AY 2012-13

Bench: Shri Rajpal Yadav & Shri Manoj Kumar Aggarwalआयकर अपील सं./ Ita No. 303/Chd/2019 "नधा"रण वष" / Assessment Year : 2012-13 Shri Satish Soin, बनाम The Acit, House No.31, Garden Enclave, Central Circle-2, Vs South City-Ii, Ludhiana. Ludhiana. "थायी लेखा सं./Pan /Tan No: Advps6254N अपीलाथ"/Appellant ""यथ"/Respondent "नधा"रती क" ओर से/Assessee By : Shri Ashwani Kumar & Ms. Muskan Garg, Cas राज"व क" ओर से/ Revenue By : Smt. Kusum Bansal, Cit Dr तार"ख/Date Of Hearing : 26.05.2025 उदघोषणा क" तार"ख/Date Of Pronouncement : 23.07.2025 Hybrid Hearing आदेश/Order Per Rajpal Yadav, Vp

For Appellant: Shri Ashwani Kumar &For Respondent: Smt. Kusum Bansal, CIT DR
Section 10(38)Section 132Section 143(3)Section 153ASection 153DSection 263

during the search and other material which would include income declared in the returns, if any, furnished by the assessee as well as the undisclosed income. However, in case during the search no incriminating material is found, in case of completed/unabated assessment, the only remedy available to the Revenue would ... with the search and requisition under Sections 132 and 132A of the Act. The object of Section 153A is to bring under tax the undisclosed income which is found during the course of search or pursuant to search or requisition. Therefore, only in a case where the undisclosed income

Kathir Kaman Jewels Pvt. Ltd., Chennai vs. DCIT, Central Circle -3(1), Chennai

In the result, all the appeals filed by the assessee are allowed for statistical purposes

ITA 20/CHNY/2025[2016-17]Status: DisposedITAT Chennai23 Jul 2025AY 2016-17

Bench: Shri S.S. Viswanethra Ravi & Shri Jagadishआयकर अपील सं./I.T.A. Nos.17, 18, 19 & 20/Chny/2025 िनधा"रण वष"/Assessment Years: 2011-12, 2012-13, 2015-16 & 2016-17 Kathir Kaman Jewels Pvt. Ltd., Vs. The Deputy Commissioner Of New No. 40 (Old No. 23), Sarojini Income Tax, Street, T. Nagar, Chennai 600 017. Central Circle 3(1) Chennai. [Pan:Aacck4534C] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri T. Banusekar, Advocate & Shri H. Yeshwanth Kumar, Advocate ""थ" की ओर से/Respondent By : Shri C.N. Bipin, Cit सुनवाई की तारीख/ Date Of Hearing : 24.06.2025 घोषणा की तारीख /Date Of Pronouncement : 23.07.2025 आदेश /O R D E R Per S.S. Viswanethra Ravi: These Appeals Filed By The Assessee Are Directed Against Different Orders All Dated 17.10.2024 Passed By The Ld. Commissioner Of Income Tax (Appeals) – 20, Chennai For The Assessment Years 2011-12, 2012-13, 2015-16 & 2016-17. 2. Since Issues Raised In These Appeals Are Similar Based On The Same Identical Facts, With The Consent Of The Both The Parties, We Proceed To 2

For Appellant: Shri T. Banusekar, Advocate &For Respondent: Shri C.N. Bipin, CIT
Section 132Section 132(4)Section 139Section 142(1)Section 143(1)Section 143(2)Section 143(3)Section 153C

issue emanates for our consideration as to whether the ld. CIT(A) is justified in confirming the addition made by the Assessing Officer towards undisclosed income by concluding the assessment under section 143(3) r.w.s. 153C of the Income Tax Act, 1961 [“Act” in short] in the facts and circumstances ... recorded from Shri B. Ayyappan on 20.01.2017, wherein, he accepted that the assessee had unaccounted income and admitted undisclosed income of ₹.11,51,18,827/- in the hands of assessee for the AY 2011-12, AY 2012-13, AY 2015-16 and AY 2016-17. Considering the satisfaction note recorded

Kathir Kaman Jewels Pvt. Ltd., Chennai vs. DCIT, Central Circle-3(1), Chennai

In the result, all the appeals filed by the assessee are allowed for statistical purposes

ITA 19/CHNY/2025[2015-16]Status: DisposedITAT Chennai23 Jul 2025AY 2015-16

Bench: Shri S.S. Viswanethra Ravi & Shri Jagadishआयकर अपील सं./I.T.A. Nos.17, 18, 19 & 20/Chny/2025 िनधा"रण वष"/Assessment Years: 2011-12, 2012-13, 2015-16 & 2016-17 Kathir Kaman Jewels Pvt. Ltd., Vs. The Deputy Commissioner Of New No. 40 (Old No. 23), Sarojini Income Tax, Street, T. Nagar, Chennai 600 017. Central Circle 3(1) Chennai. [Pan:Aacck4534C] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri T. Banusekar, Advocate & Shri H. Yeshwanth Kumar, Advocate ""थ" की ओर से/Respondent By : Shri C.N. Bipin, Cit सुनवाई की तारीख/ Date Of Hearing : 24.06.2025 घोषणा की तारीख /Date Of Pronouncement : 23.07.2025 आदेश /O R D E R Per S.S. Viswanethra Ravi: These Appeals Filed By The Assessee Are Directed Against Different Orders All Dated 17.10.2024 Passed By The Ld. Commissioner Of Income Tax (Appeals) – 20, Chennai For The Assessment Years 2011-12, 2012-13, 2015-16 & 2016-17. 2. Since Issues Raised In These Appeals Are Similar Based On The Same Identical Facts, With The Consent Of The Both The Parties, We Proceed To 2

For Appellant: Shri T. Banusekar, Advocate &For Respondent: Shri C.N. Bipin, CIT
Section 132Section 132(4)Section 139Section 142(1)Section 143(1)Section 143(2)Section 143(3)Section 153C

issue emanates for our consideration as to whether the ld. CIT(A) is justified in confirming the addition made by the Assessing Officer towards undisclosed income by concluding the assessment under section 143(3) r.w.s. 153C of the Income Tax Act, 1961 [“Act” in short] in the facts and circumstances ... recorded from Shri B. Ayyappan on 20.01.2017, wherein, he accepted that the assessee had unaccounted income and admitted undisclosed income of ₹.11,51,18,827/- in the hands of assessee for the AY 2011-12, AY 2012-13, AY 2015-16 and AY 2016-17. Considering the satisfaction note recorded