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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

Exel Rubber Private Limited, Hyderabad vs. DCIT, Central Circle-1(2), Hyderabad

In the result, the appeal of the assessee is allowed

ITA 1895/HYD/2025[2022-23]Status: DisposedITAT Hyderabad18 Feb 2026AY 2022-23

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Manjunatha G.आ.अपी.सं /Ita No.1895/Hyd/2025 (िनधा"रण वष"/Assessment Year: 2022-23) M/S. Exel Rubber (P) Ltd Vs. Dy.Cit Hyderabad Central Circle 1(2) Pan:Aaace4495J Hyderabad (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri M.V. Prasad, Ca राज" व "ारा/Revenue By: Dr. Narendra Kumar Naik, Cit (Dr) सुनवाई की तारीख/Date Of Hearing: 20/01/2026 घोषणा की तारीख/Pronouncement: 18/02/2026 आदेश/Order Per Manjunatha, G. A.M. This Appeal Is Filed By The Assessee Is Directed Against The Order Passed By The Learned Commissioner Of Income Tax (Appeals)-11, Hyderabad Dated 09/10/2025 For The A.Y 2022-23. 2. The Assessee Has Raised The Following Grounds Of Appeal:

For Appellant: Shri M.V. Prasad, CAFor Respondent: Dr. Narendra Kumar Naik, CIT (DR)
Section 143(2)Section 153Section 250

entries contained in FOCUS 5.5 software. The A.O after considering the relevant submissions of the assessee and also taking note of admission of undisclosed income during the course of search, has made addition of Rs.2,31,58,002/- towards undisclosed income as per the transactions entered in FOCUS 5.5 software ... Exel Rubber P Ltd 2022-23 liable to be quashed. The assessee also challenged the additions made by the A.O towards undisclosed income on the basis of FOCUS 5.5 software. The Ld. CIT (A) rejected the legal ground taken by the assessee challenging the validity of assessment proceedings and adjudicated

Exel Rubber Private Limited, Hyderabad vs. DCIT, Central Circle-1(2), Hyderabad

In the result, appeal filed by the assessee is allowed

ITA 1894/HYD/2025[2014-15]Status: DisposedITAT Hyderabad18 Feb 2026AY 2014-15

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Manjunatha G.आ.अपी.सं /Ita No.1894/Hyd/2025 (िनधा"रण वष"/Assessment Year: 2014-15) M/S. Exel Rubber (P) Ltd Vs. Dy.Cit Hyderabad Central Circle 1(2) Pan:Aaace4495J Hyderabad (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri M.V. Prasad, Ca राज" व "ारा/Revenue By: Dr. Narendra Kumar Naik, Cit (Dr) सुनवाई की तारीख/Date Of Hearing: 20/01/2026 घोषणा की तारीख/Pronouncement: 18/02/2026 आदेश/Order Per Manjunatha, G. A.M. This Appeal Is Filed By The Assessee Is Directed Against The Order Passed By The Learned Commissioner Of Income Tax (Appeals)-11 Hyderabad, Dated 11/10/2025 For The A.Y 2014-15. 2. The Assessee Has Raised The Following Grounds Of Appeal:

For Appellant: Shri M.V. Prasad, CAFor Respondent: Dr. Narendra Kumar Naik, CIT (DR)
Section 132Section 143(2)Section 143(3)Section 147Section 148Section 149(1)Section 69A

income on 03.02.2024 admitting total income of Rs.39,47,11,554/-. The assessee admitted an additional income of Rs.1,98,15,318/- towards undisclosed income out of cash receipts as per entries in Focus 5.5 software found during the search proceedings. The assessee vide letter dated 06.02.2024 furnished computation ... reasons recorded placed at Page Nos.9 & 10 of the paper book and submitted that the Assessing Officer has given the details of year-wise undisclosed income quantified by the ADIT which satisfies the condition u/s 149(1)(b)(i) and (iii) of the Act. He has further submitted that

Ace Tyres Private Limited, Hyderabad vs. DCIT, Central Circle-1(2), Hyderabad

In the result, the appeal of the assessee is allowed

ITA 1893/HYD/2025[2022-23]Status: DisposedITAT Hyderabad18 Feb 2026AY 2022-23

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Manjunatha G.आ.अपी.सं /Ita No.1893/Hyd/2025 (िनधा"रण वष"/Assessment Year: 2022-23) M/S. Ace Tyres (P) Ltd Vs. Dy.Cit Hyderabad Central Circle (1)2 Pan:Aadca2210N Hyderabad (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri M.V. Prasad, Ca राज" व "ारा/Revenue By: Dr. Narendra Kumar Naik, Cit (Dr) सुनवाई की तारीख/Date Of Hearing: 20/01/2026 घोषणा की तारीख/Pronouncement: 18/02/2026 आदेश/Order Per. Manjunatha, G. A.M. This Appeal Is Filed By The Assessee Directed Against The Order Passed By The Learned Commissioner Of Income Tax (Appeals)-11, Hyderabad, Dated 16/10/2025 For The A.Y 2022-23. 2. The Assessee Has Raised The Following Grounds Of Appeal:

For Appellant: Shri M.V. Prasad, CAFor Respondent: Dr. Narendra Kumar Naik, CIT
Section 143(2)Section 148Section 153

entries contained in FOCUS 5.5 software. The A.O after considering the relevant submissions of the assessee and also taking note of admission of undisclosed income during the course of search, has made addition of Rs.2,04,91,041/- towards undisclosed income as per the transactions entered in FOCUS 5.5 software ... liable to be quashed. The assessee also challenged the additions made by the A.O towards undisclosed income on the basis of FOCUS 5.5 software. The Ld. CIT (A) rejected the legal ground taken by the assessee challenging the validity of assessment proceedings and adjudicated the issues raised in appeal

Vilas Polymer Private Limited, Hyderabad vs. DCIT, Central Circle-1(2), Hyderabad

In the result, the appeal of the assessee allowed

ITA 1885/HYD/2025[2022-23]Status: DisposedITAT Hyderabad18 Feb 2026AY 2022-23

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Manjunatha G.आ.अपी.सं /Ita No.1885/Hyd/2025 (िनधा"रण वष"/Assessment Year: 2022-23) M/S. Vilas Polymer (P) Ltd Vs. Dy.Cit Hyderabad Central Circle 1(2) Pan:Aaacv9854A Hyderabad (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri M.V. Prasad, Ca राज" व "ारा/Revenue By: Dr. Narendra Kumar Naik, Cit (Dr) सुनवाई की तारीख/Date Of Hearing: 19/01/2026 घोषणा की तारीख/Pronouncement: 18/02/2026 आदेश/Order Per Manjunatha, G. A.M. This Appeal Is Filed By The Assessee Is Directed Against The Order Passed By The Learned Commissioner Of Income Tax (Appeals)-11, Hyderabad, Dated 31/10/2025 For The A.Y 2022-23. 2. The Assessee Has Raised The Following Grounds Of Appeal:

For Appellant: Shri M.V. Prasad, CAFor Respondent: Dr. Narendra Kumar Naik, CIT
Section 143(2)Section 153

assessee company has challenged the legal ground regarding the assessment barred by limitation and also challenged the additions made by the A.O towards undisclosed income on the basis of FOCUS 5.5 software and undisclosed business receipts as per the evidence found in VPPL Office. The Ld. CIT (A) dismissed ... legal ground and adjudicated the factual ground on merits and allowed partial relief in respect of addition towards undisclosed income from sales of scrap, etc., and directed the AO to make addition of Rs.6,79,72,473/- as against the additions made by the AO for Rs.7

Vilas Polymer Private Limited, Hyderabad vs. DCIT, Central Circle-1(2), Hyderabad

In the result, the appeal of the assessee is allowed

ITA 1884/HYD/2025[2021-22]Status: DisposedITAT Hyderabad18 Feb 2026AY 2021-22

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Manjunatha G.आ.अपी.सं /Ita Nos.1876 & 1884/Hyd/2025 (िनधा"रण वष"/Assessment Years: 2020-21 & 2021-22) M/S. Vilas Polymer (P) Ltd Vs. Dy.Cit Hyderabad Central Circle 1(2) Pan:Aaacv9854A Hyderabad (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri M.V. Prasad, Ca राज" व "ारा/Revenue By: Dr. Narendra Kumar Naik, Cit (Dr) सुनवाई की तारीख/Date Of Hearing: 19/01/2026 घोषणा की तारीख/Pronouncement: 18/02/2026 आदेश/Order Per Manjunatha, G. A.M. These Two Appeals Are Filed By The Assessee & Are Directed Against The Two Separate Orders Passed By The Learned Commissioner Of Income Tax (Appeals)-11, Hyderabad, Both Dated 31/10/2025, For The Asst. Years 2020-21 & 2021-22 Respectively. Since Identical Issues Are Involved In These Two Appeals, For The Sake Of Convenience, These Two Appeals Were Heard Together & Are Being Disposed Off, By This Common Consolidated Order.

For Appellant: Shri M.V. Prasad, CAFor Respondent: Dr. Narendra Kumar Naik, CIT (DR)
Section 132Section 132(4)Section 143(1)Section 143(3)Section 148

entries contained in FOCUS 5.5 software. The A.O after considering the relevant submissions of the assessee and also taking note of admission of undisclosed income during the course of search, has made addition of Rs.1,20,69,073/- towards undisclosed income as per the transactions entered in FOCUS 5.5 software ... also made addition of Rs.71,86,830/- towards unaccounted income generated from the factory at Pashamylaram towards undisclosed income as per evidence found in assessee office. 6. Aggrieved by the assessment order, the assessee preferred an appeal before the Ld. CIT (A). During the course of appellate proceedings, the assessee

Vilas Polymer Private Limited, Hyderabad vs. DCIT, Central Circle-1(2), Hyderabad

In the result, the appeal of the assessee is allowed

ITA 1876/HYD/2025[2020-21]Status: DisposedITAT Hyderabad18 Feb 2026AY 2020-21

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Manjunatha G.आ.अपी.सं /Ita Nos.1876 & 1884/Hyd/2025 (िनधा"रण वष"/Assessment Years: 2020-21 & 2021-22) M/S. Vilas Polymer (P) Ltd Vs. Dy.Cit Hyderabad Central Circle 1(2) Pan:Aaacv9854A Hyderabad (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri M.V. Prasad, Ca राज" व "ारा/Revenue By: Dr. Narendra Kumar Naik, Cit (Dr) सुनवाई की तारीख/Date Of Hearing: 19/01/2026 घोषणा की तारीख/Pronouncement: 18/02/2026 आदेश/Order Per Manjunatha, G. A.M. These Two Appeals Are Filed By The Assessee & Are Directed Against The Two Separate Orders Passed By The Learned Commissioner Of Income Tax (Appeals)-11, Hyderabad, Both Dated 31/10/2025, For The Asst. Years 2020-21 & 2021-22 Respectively. Since Identical Issues Are Involved In These Two Appeals, For The Sake Of Convenience, These Two Appeals Were Heard Together & Are Being Disposed Off, By This Common Consolidated Order.

For Appellant: Shri M.V. Prasad, CAFor Respondent: Dr. Narendra Kumar Naik, CIT (DR)
Section 132Section 132(4)Section 143(1)Section 143(3)Section 148

entries contained in FOCUS 5.5 software. The A.O after considering the relevant submissions of the assessee and also taking note of admission of undisclosed income during the course of search, has made addition of Rs.1,20,69,073/- towards undisclosed income as per the transactions entered in FOCUS 5.5 software ... also made addition of Rs.71,86,830/- towards unaccounted income generated from the factory at Pashamylaram towards undisclosed income as per evidence found in assessee office. 6. Aggrieved by the assessment order, the assessee preferred an appeal before the Ld. CIT (A). During the course of appellate proceedings, the assessee

Exel Rubber Private Limited, Hyderabad vs. DCIT., Central Circle-1(2), Hyderabad

ITA 1566/HYD/2025[2020-21]Status: DisposedITAT Hyderabad18 Feb 2026AY 2020-21

Bench: Shri Vijay Pal Rao, Vice- & Shri Manjunatha G.आ. अपी.सं / Ita Nos.1566 & 1571/Hyd/2025 (निर्धारण वर्ष/Assessment Years: 2020-21 & 2021-22) M/S. Exel Rubber Private Ltd Vs. Hyderabad Dy.Cit Central Circle 1 (2) Hyderabad Pan:Aaace4495J (Appellant) (Respondent) निर्धारिती द्वारा / Assessee By: Shri M.V. Prasad, Ca राजस्व द्वारा/Revenue By: Dr. Narendra Kumar Naik, Cit (Dr) सुनवाई की तारीख / Date Of Hearing: 20/01/2026 घोषणा की तारीख / Pronouncement: 18/02/2026 Per Manjunatha, G. A.M. आदेश/Order These Two Appeals Filed By The Assessee Are Directed Against The Separate Orders Passed By The Learned Commissioner Of Income Tax (Appeals)-11, Hyderabad, Both Dated 14/07/2025 For The A.Ys 2020-21, 2021-22 & 2022-23 Respectively. Since Common Issues Are Involved In These Two Appeals, For The Sake Of Convenience, These Were Heard Together & Are Being Disposed Of By This Common Consolidated Order.

For Appellant: Shri M.V. Prasad, CAFor Respondent: Dr. Narendra Kumar Naik, CIT (DR)
Section 132Section 132(4)Section 143(3)Section 148

entries contained in FOCUS 5.5 software. The A.O after considering the relevant submissions of the assessee and also taking note of admission of undisclosed income during the course of search, has made addition of Rs.62,16,740/-towards adjustment purchase transactions. Page ... under section 132 of the Act it was found that the assessee has unaccounted cash receipts from scrap sale and the assessee had admitted undisclosed income of Rs.3,55,81,180/- for the year under consideration. These unaccounted cash receipts have resulted in suppression of income and escapement of income