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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

Sh. Satpal Singh, Meerut vs. ITO, Meerut

The appeal of the assessee is dismissed

ITA 2761/DEL/2013[2007-08]Status: DisposedITAT Delhi29 Dec 2025AY 2007-08

Bench: Shri Yogesh Kumar U.S. & Shri Naveen Chandrash. Satpal Singh, Income Tax Officer, C/O Sh. P.K. Dublish, Ward-2 (3), Meerut. Advocate, 205/5, Vs. Thapar Nagar, Meerut. Pan-Bllps5466B (Appellant) (Respondent) Appellant By None Respondent By Ms. Harpreet Kaur Hansra, Sr. Dr Date Of Hearing 16.12.2025 Date Of Pronouncement 29.12.2025 Order Per Yogesh Kumar U.S., Jm: This Appeal Is Filed By The Assessee Against The Order Of Learned Commissioner Of Income Tax (Appeals), Meerut [“Ld.Cit(A)”, For Short], Dated 16.12.2010 Pertaining To Assessment Year 2007-08. 2. Brief Facts Of The Case Are That The Assessment Order Came To Be Passed On 29.12.2009 U/S 1243(3) Of The Act By Making The Following Additions: I. Rs.1,49,761/- On Account Of Gross Profit On Suppressed Sales. Ii. Rs.1,16,750/- On Account Of Unexplained Capital. Iii. Rs.16,00,000/- On Account Of Unexplained Income. Iv. Rs.36,87,216/- Towards Unexplained Debtors. Satpal Singh Vs. Ito 3. Aggrieved By The Assessment Order Dated 29.12.2009, Assessee Preferred An Appeal Before The Ld. Cit(A). The Ld. Cit(A) Vide Order Dated 16.10.2010 Dismissed The Appeal Of The Assessee. As Against The Order Of The Ld. Cit(A) Dated 16.10.2010, Assessee Preferred The Present Appeal.

Section 124Section 133(6)Section 142(1)Section 143(3)

suppressed sales, which prove that the assessee has nothing to say. Therefore, in view of the above, a sum of Rs 1.16,750/- as undisclosed income is added to the income of the assessee. (Addition Rs. 1,16,750/-) Further, as per the balance sheet and capital account

DCIT., Central Circle-1(3), Hyderabad vs. Light House Movie Makers LLP, Hyderabad

In the result, the appeal filed by the revenue is dismissed

ITA 319/HYD/2024[2020-21]Status: DisposedITAT Hyderabad24 Dec 2025AY 2020-21

Bench: Shri Manjunatha G & Shri Ravish Soodआ.अपी.सं / Ita No.297/Hyd/2024 (निर्धारण वर्ष/Assessment Year:2015-16) Vs. Dy. Commissioner Of Income Tax, Central Circle 1(3), Hyderabad. (Appellant) Shri Atchi Reddy Kovvuri, Hyderabad Pan: Adopk6018R (Respondent) आ.अपी.सं / Ita Nos.318 & 319/Hyd/2024 (निर्धारण वर्ष/Assessment Years:2019-20 & 2020-21) Vs. M/S. Light House Movie Makers Llp, Hyderabad. Dy. Commissioner Of Income Tax, Central Circle 1(3), Hyderabad. (Appellant) Pan: Aagfl8979H (Respondent) निर्धारिती द्वारा / Assessees By: राजस्व द्वारा / Revenue By: सुनवाई की तारीख /Date Of Hearing: घोषणा की तारीख / Pronouncement: Shri A. Srinivas, C.A. Smt. U Mini Chandran, Cit-Dr 18/11/2025 24/12/2025 आदेश/Order Per Manjunatha G, A.М. : These Appeals Are Filed By Revenue Against The Separate Orders Passed By The Learned Commissioner Of Income Tax (Appeals)-11, Hyderabad, All Dated 19.11.2024 For The

Section 132Section 139Section 142(1)Section 153C

basis of material collected during the course of assessment proceedings in the case of searched person which does not show any light of undisclosed income of the assessee. 5. The Ld. CIT(A), after considering the relevant submissions and also taking note of certain judicial precedences and also the decision ... UPF/RP/EL-31 (pages 84 to 91), but there is no discussion as to how these loose sheets translate into any information of undisclosed income in the hands of the assessee and to which assessment year such income pertains to. Further, although the Assessing Officer referred to the table in point no.6

DCIT., Central Circle-1(3), Hyderabad vs. Light House Movie Makers LLP, Hyderabad

In the result, both the appeals filed by the revenue are dismissed

ITA 318/HYD/2024[2019-20]Status: DisposedITAT Hyderabad24 Dec 2025AY 2019-20

Bench: Shri Manjunatha G & Shri Ravish Soodआ.अपी.सं /Ita No.297/Hyd/2024 (निर्धारण वर्ा/Assessment Year:2015-16) Dy. Commissioner Of Income Shri Atchi Reddy Kovvuri, Vs. Hyderabad Tax, Pan : Adopk6018R Central Circle 1(3), Hyderabad. (Appellant) (Respondent) आ.अपी.सं /Ita Nos.318 & 319/Hyd/2024 (निर्धारण वर्ा/Assessment Years:2019-20 & 2020-21) Dy. Commissioner Of Income M/S. Light House Movie Makers Vs. Llp, Hyderabad. Tax, Pan : Aagfl8979H Central Circle 1(3), Hyderabad. (Appellant) (Respondent) निर्धाररती द्वधरध/Assessees By: Shri A. Srinivas, C.A. रधजस् व द्वधरध/Revenue By: Smt. U Mini Chandran, Cit-Dr सुिवधई की तधरीख/Date Of Hearing: 18/11/2025 घोर्णध की तधरीख/Pronouncement: 24/12/2025 आदेश/Order Per Manjunatha G, A.M. : These Appeals Are Filed By Revenue Against The Separate Orders Passed By The Learned Commissioner Of Income Tax (Appeals)-11, Hyderabad, All Dated 19.11.2024 For The

For Respondent: Smt. U Mini Chandran, CIT-DR
Section 132Section 139Section 142(1)Section 153C

during the course of ITA Nos.297, 318 & 319/Hyd/2024 5 assessment proceedings in the case of searched person which does not show any light of undisclosed income of the assessee. 5. The Ld. CIT(A), after considering the relevant submissions and also taking note of certain judicial precedences and also ... UPF/RP/EL-31 (pages 84 to 91), but there is no discussion as to how these loose sheets translate into any information of undisclosed income in the hands of the assessee and to which assessment year such income pertains to. Further, although the Assessing Officer referred to the table in point no.6

DCIT., Central Circle-1(3), Hyderabad vs. Atchi Reddy Kovuuri, Hhyderabad

In the result, both the appeals filed by the revenue are dismissed

ITA 297/HYD/2024[2015-16]Status: DisposedITAT Hyderabad24 Dec 2025AY 2015-16

Bench: Shri Manjunatha G & Shri Ravish Soodआ.अपी.सं /Ita No.297/Hyd/2024 (निर्धारण वर्ा/Assessment Year:2015-16) Dy. Commissioner Of Income Shri Atchi Reddy Kovvuri, Vs. Hyderabad Tax, Pan : Adopk6018R Central Circle 1(3), Hyderabad. (Appellant) (Respondent) आ.अपी.सं /Ita Nos.318 & 319/Hyd/2024 (निर्धारण वर्ा/Assessment Years:2019-20 & 2020-21) Dy. Commissioner Of Income M/S. Light House Movie Makers Vs. Llp, Hyderabad. Tax, Pan : Aagfl8979H Central Circle 1(3), Hyderabad. (Appellant) (Respondent) निर्धाररती द्वधरध/Assessees By: Shri A. Srinivas, C.A. रधजस् व द्वधरध/Revenue By: Smt. U Mini Chandran, Cit-Dr सुिवधई की तधरीख/Date Of Hearing: 18/11/2025 घोर्णध की तधरीख/Pronouncement: 24/12/2025 आदेश/Order Per Manjunatha G, A.M. : These Appeals Are Filed By Revenue Against The Separate Orders Passed By The Learned Commissioner Of Income Tax (Appeals)-11, Hyderabad, All Dated 19.11.2024 For The

For Respondent: Smt. U Mini Chandran, CIT-DR
Section 132Section 139Section 142(1)Section 153C

during the course of ITA Nos.297, 318 & 319/Hyd/2024 5 assessment proceedings in the case of searched person which does not show any light of undisclosed income of the assessee. 5. The Ld. CIT(A), after considering the relevant submissions and also taking note of certain judicial precedences and also ... UPF/RP/EL-31 (pages 84 to 91), but there is no discussion as to how these loose sheets translate into any information of undisclosed income in the hands of the assessee and to which assessment year such income pertains to. Further, although the Assessing Officer referred to the table in point no.6

Dy Commissioner of Income Tax, Noida vs. Surender Gupta, Delhi

In the result, the appeal of the assessee is partly allowed and of the Revenue is dismissed as discussed hereinabove

ITA 2873/DEL/2025[2020-21]Status: DisposedITAT Delhi24 Dec 2025AY 2020-21

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwalita Nos.1670 To 1672/Del/2025 (Assessment Years 2018-19, 2019-20 & 2020-21) Surender Gupta, Dy. Cit, A-27, Phase-1, Ashok Vihar, Central Circle-30, H.O. North West Delhi-110052. Vs. Delhi. Pan-Aaopg2234J (Appellant) (Respondent) Ita Nos.2871 To 2873/Del/2025 (Assessment Years 2018-19, 2019-20 & 2020-21) Dy. Cit, Surender Gupta, Central Circle-1, A-27, Phase-1, Ashok Vihar, Noida. Vs. H.O. North West Delhi-110052. Pan-Aaopg2234J (Appellant) (Respondent) Assessee By Shri Mayank Patwari, Adv. & Shri Aakash Ojha, Adv. Department By Ms. Rajinder Kaur, Cit-Dr Date Of Hearing 20.11.2025 Date Of Pronouncement 24.12.2025 O R D E R Per Manish Agarwal, Am: The Captioned Cross Appeals Are Filed By The Assessee & Revenue Against Three Separate Orders Of Ld. Commissioner Of Income Tax (Appeals)-30, New Delhi [“Ld. Cit(A) In Short”] U/S 250 Of The Income Tax Act, 1961 [“The Act In Short”], All Are Dated 24.02.2025 Against The Orders Of The Assessing Officer U/S 153A R.W.S Ita Nos.2871 To 2873/Del/2025 Surender Gupta Vs. Dcit 143(3) Of The Income Tax Act, 1961 (“The Act” For Short) For Assessment Years 2018-19, 2019-20 & 2020-21 Respectively.

Section 127Section 139(1)Section 153ASection 153DSection 250

found to be engaged in taking accommodation entries in the shape of bogus purchases, entire amount of purchases deserves to be held as undisclosed income of the assessee and, therefore, he prayed for restoration of the addition made by the AO on this account. 12. Heard both the parties

Dy. Commissioner of Income Tax, Central Circle-I, Noida vs. Surender Gupta, Delhi

In the result, the appeal of the assessee is partly allowed and of the Revenue is dismissed as discussed hereinabove

ITA 2872/DEL/2025[2019-20]Status: DisposedITAT Delhi24 Dec 2025AY 2019-20

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwalita Nos.1670 To 1672/Del/2025 (Assessment Years 2018-19, 2019-20 & 2020-21) Surender Gupta, Dy. Cit, A-27, Phase-1, Ashok Vihar, Central Circle-30, H.O. North West Delhi-110052. Vs. Delhi. Pan-Aaopg2234J (Appellant) (Respondent) Ita Nos.2871 To 2873/Del/2025 (Assessment Years 2018-19, 2019-20 & 2020-21) Dy. Cit, Surender Gupta, Central Circle-1, A-27, Phase-1, Ashok Vihar, Noida. Vs. H.O. North West Delhi-110052. Pan-Aaopg2234J (Appellant) (Respondent) Assessee By Shri Mayank Patwari, Adv. & Shri Aakash Ojha, Adv. Department By Ms. Rajinder Kaur, Cit-Dr Date Of Hearing 20.11.2025 Date Of Pronouncement 24.12.2025 O R D E R Per Manish Agarwal, Am: The Captioned Cross Appeals Are Filed By The Assessee & Revenue Against Three Separate Orders Of Ld. Commissioner Of Income Tax (Appeals)-30, New Delhi [“Ld. Cit(A) In Short”] U/S 250 Of The Income Tax Act, 1961 [“The Act In Short”], All Are Dated 24.02.2025 Against The Orders Of The Assessing Officer U/S 153A R.W.S Ita Nos.2871 To 2873/Del/2025 Surender Gupta Vs. Dcit 143(3) Of The Income Tax Act, 1961 (“The Act” For Short) For Assessment Years 2018-19, 2019-20 & 2020-21 Respectively.

Section 127Section 139(1)Section 153ASection 153DSection 250

found to be engaged in taking accommodation entries in the shape of bogus purchases, entire amount of purchases deserves to be held as undisclosed income of the assessee and, therefore, he prayed for restoration of the addition made by the AO on this account. 12. Heard both the parties

Dy. Commissioner of Income Tax, Central Circle I Noida, Noida vs. Surender Gupta, Delhi

In the result, the appeal of the assessee is partly allowed and of the Revenue is dismissed as discussed hereinabove

ITA 2871/DEL/2025[2018-19]Status: DisposedITAT Delhi24 Dec 2025AY 2018-19

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwalita Nos.1670 To 1672/Del/2025 (Assessment Years 2018-19, 2019-20 & 2020-21) Surender Gupta, Dy. Cit, A-27, Phase-1, Ashok Vihar, Central Circle-30, H.O. North West Delhi-110052. Vs. Delhi. Pan-Aaopg2234J (Appellant) (Respondent) Ita Nos.2871 To 2873/Del/2025 (Assessment Years 2018-19, 2019-20 & 2020-21) Dy. Cit, Surender Gupta, Central Circle-1, A-27, Phase-1, Ashok Vihar, Noida. Vs. H.O. North West Delhi-110052. Pan-Aaopg2234J (Appellant) (Respondent) Assessee By Shri Mayank Patwari, Adv. & Shri Aakash Ojha, Adv. Department By Ms. Rajinder Kaur, Cit-Dr Date Of Hearing 20.11.2025 Date Of Pronouncement 24.12.2025 O R D E R Per Manish Agarwal, Am: The Captioned Cross Appeals Are Filed By The Assessee & Revenue Against Three Separate Orders Of Ld. Commissioner Of Income Tax (Appeals)-30, New Delhi [“Ld. Cit(A) In Short”] U/S 250 Of The Income Tax Act, 1961 [“The Act In Short”], All Are Dated 24.02.2025 Against The Orders Of The Assessing Officer U/S 153A R.W.S Ita Nos.2871 To 2873/Del/2025 Surender Gupta Vs. Dcit 143(3) Of The Income Tax Act, 1961 (“The Act” For Short) For Assessment Years 2018-19, 2019-20 & 2020-21 Respectively.

Section 127Section 139(1)Section 153ASection 153DSection 250

found to be engaged in taking accommodation entries in the shape of bogus purchases, entire amount of purchases deserves to be held as undisclosed income of the assessee and, therefore, he prayed for restoration of the addition made by the AO on this account. 12. Heard both the parties

Surender Gupta, Delhi vs. DCIT, Central Circle-30, Delhi

In the result, the appeal of the assessee is partly allowed and of the Revenue is dismissed as discussed hereinabove

ITA 1672/DEL/2025[2020-21]Status: DisposedITAT Delhi24 Dec 2025AY 2020-21

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwalita Nos.1670 To 1672/Del/2025 (Assessment Years 2018-19, 2019-20 & 2020-21) Surender Gupta, Dy. Cit, A-27, Phase-1, Ashok Vihar, Central Circle-30, H.O. North West Delhi-110052. Vs. Delhi. Pan-Aaopg2234J (Appellant) (Respondent) Ita Nos.2871 To 2873/Del/2025 (Assessment Years 2018-19, 2019-20 & 2020-21) Dy. Cit, Surender Gupta, Central Circle-1, A-27, Phase-1, Ashok Vihar, Noida. Vs. H.O. North West Delhi-110052. Pan-Aaopg2234J (Appellant) (Respondent) Assessee By Shri Mayank Patwari, Adv. & Shri Aakash Ojha, Adv. Department By Ms. Rajinder Kaur, Cit-Dr Date Of Hearing 20.11.2025 Date Of Pronouncement 24.12.2025 O R D E R Per Manish Agarwal, Am: The Captioned Cross Appeals Are Filed By The Assessee & Revenue Against Three Separate Orders Of Ld. Commissioner Of Income Tax (Appeals)-30, New Delhi [“Ld. Cit(A) In Short”] U/S 250 Of The Income Tax Act, 1961 [“The Act In Short”], All Are Dated 24.02.2025 Against The Orders Of The Assessing Officer U/S 153A R.W.S Ita Nos.2871 To 2873/Del/2025 Surender Gupta Vs. Dcit 143(3) Of The Income Tax Act, 1961 (“The Act” For Short) For Assessment Years 2018-19, 2019-20 & 2020-21 Respectively.

Section 127Section 139(1)Section 153ASection 153DSection 250

found to be engaged in taking accommodation entries in the shape of bogus purchases, entire amount of purchases deserves to be held as undisclosed income of the assessee and, therefore, he prayed for restoration of the addition made by the AO on this account. 12. Heard both the parties

Surender Gupta, Delhi vs. DCIT, Central Circle-30, Delhi

In the result, the appeal of the assessee is partly allowed and of the Revenue is dismissed as discussed hereinabove

ITA 1671/DEL/2025[2019-20]Status: DisposedITAT Delhi24 Dec 2025AY 2019-20

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwalita Nos.1670 To 1672/Del/2025 (Assessment Years 2018-19, 2019-20 & 2020-21) Surender Gupta, Dy. Cit, A-27, Phase-1, Ashok Vihar, Central Circle-30, H.O. North West Delhi-110052. Vs. Delhi. Pan-Aaopg2234J (Appellant) (Respondent) Ita Nos.2871 To 2873/Del/2025 (Assessment Years 2018-19, 2019-20 & 2020-21) Dy. Cit, Surender Gupta, Central Circle-1, A-27, Phase-1, Ashok Vihar, Noida. Vs. H.O. North West Delhi-110052. Pan-Aaopg2234J (Appellant) (Respondent) Assessee By Shri Mayank Patwari, Adv. & Shri Aakash Ojha, Adv. Department By Ms. Rajinder Kaur, Cit-Dr Date Of Hearing 20.11.2025 Date Of Pronouncement 24.12.2025 O R D E R Per Manish Agarwal, Am: The Captioned Cross Appeals Are Filed By The Assessee & Revenue Against Three Separate Orders Of Ld. Commissioner Of Income Tax (Appeals)-30, New Delhi [“Ld. Cit(A) In Short”] U/S 250 Of The Income Tax Act, 1961 [“The Act In Short”], All Are Dated 24.02.2025 Against The Orders Of The Assessing Officer U/S 153A R.W.S Ita Nos.2871 To 2873/Del/2025 Surender Gupta Vs. Dcit 143(3) Of The Income Tax Act, 1961 (“The Act” For Short) For Assessment Years 2018-19, 2019-20 & 2020-21 Respectively.

Section 127Section 139(1)Section 153ASection 153DSection 250

found to be engaged in taking accommodation entries in the shape of bogus purchases, entire amount of purchases deserves to be held as undisclosed income of the assessee and, therefore, he prayed for restoration of the addition made by the AO on this account. 12. Heard both the parties

Surender Gupta, Delhi vs. DCIT, Central Circle-30, Delhi

In the result, the appeal of the assessee is partly allowed and of the Revenue is dismissed as discussed hereinabove

ITA 1670/DEL/2025[2018-19]Status: DisposedITAT Delhi24 Dec 2025AY 2018-19

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwalita Nos.1670 To 1672/Del/2025 (Assessment Years 2018-19, 2019-20 & 2020-21) Surender Gupta, Dy. Cit, A-27, Phase-1, Ashok Vihar, Central Circle-30, H.O. North West Delhi-110052. Vs. Delhi. Pan-Aaopg2234J (Appellant) (Respondent) Ita Nos.2871 To 2873/Del/2025 (Assessment Years 2018-19, 2019-20 & 2020-21) Dy. Cit, Surender Gupta, Central Circle-1, A-27, Phase-1, Ashok Vihar, Noida. Vs. H.O. North West Delhi-110052. Pan-Aaopg2234J (Appellant) (Respondent) Assessee By Shri Mayank Patwari, Adv. & Shri Aakash Ojha, Adv. Department By Ms. Rajinder Kaur, Cit-Dr Date Of Hearing 20.11.2025 Date Of Pronouncement 24.12.2025 O R D E R Per Manish Agarwal, Am: The Captioned Cross Appeals Are Filed By The Assessee & Revenue Against Three Separate Orders Of Ld. Commissioner Of Income Tax (Appeals)-30, New Delhi [“Ld. Cit(A) In Short”] U/S 250 Of The Income Tax Act, 1961 [“The Act In Short”], All Are Dated 24.02.2025 Against The Orders Of The Assessing Officer U/S 153A R.W.S Ita Nos.2871 To 2873/Del/2025 Surender Gupta Vs. Dcit 143(3) Of The Income Tax Act, 1961 (“The Act” For Short) For Assessment Years 2018-19, 2019-20 & 2020-21 Respectively.

Section 127Section 139(1)Section 153ASection 153DSection 250

found to be engaged in taking accommodation entries in the shape of bogus purchases, entire amount of purchases deserves to be held as undisclosed income of the assessee and, therefore, he prayed for restoration of the addition made by the AO on this account. 12. Heard both the parties