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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

M/S. Bajrangbali Re-Rolles Pvt. Ltd, Rourkela vs. ACIT, Central Circle, Sambalpur

In the result, appeal of the assessee stands allowed

ITA 110/CTK/2022[2020-21]Status: HeardITAT Cuttack28 Mar 2023AY 2020-21

Bench: Before S/Shri George Mathan, Judicial & Arun Khodpia & Arun Khodpia & Arun Khodpiaassessment Year : 2020-2021 2021 M/S. Bajrangbali Re M/S. Bajrangbali Re-Rollers Vs. Acit, Acit, Central Central Circle, Circle, Pvt Pvt Ltd., Ltd., Lal Lal Building, Building, Sambalpur Sambalpur Kachery Road, Rourkela. Kachery Road, Rourkela. Pan/Gir No. Pan/Gir No.Aaccb 6678 A (Appellant (Appellant) .. ( Respondent Respondent) Assessee By Assessee By : Shri S.K.Tulsiyan, Ms Nisha Rachh & B.K.Tibrewal, Nisha Rachh & B.K.Tibrewal, Ars Revenue By : Shri M.K.Gautam, Pr. Cit (Osd) Pr. Cit (Osd) Date Of Hearing : 28 /0 03/2023 Date Of Pronouncement : 28 /0 /03/2023

For Appellant: Shri S.K.Tulsiyan, Ms Nisha Rachh and B.K.TibrewalFor Respondent: Shri M.K.Gautam, Pr. CIT (OSD)

statement recorded from the Director of the assesseee P a g e 4 | 6 Assessment Year : 2020-2021 company accepting any undisclosed income much less probable undisclosed stock. The items dealt with by the assessee admittedly are excisable commodity and GST is also leviable. In the relevant assessment year, there

M/S. Bajrangbali Steel Industries Pvt. Ltd, Rourkla vs. ACIT, Central Circle, Sambalpur

In the result, appeals of the assessee in IT(SS)A No

ITA 109/CTK/2022[2020-21]Status: DisposedITAT Cuttack28 Mar 2023AY 2020-21

Bench: Shri George Mathan & Shri Arun Khodpiaआयकर अऩीऱ (तऱाशियाां और अशिग्रहण)/It(Ss)A Nos.31 To 33/Ctk/2022 (ननधाारण वषा / Assessment Year : 2016-2017 To 2018-2019) M/S Bee Pee Rollers Pvt. Ltd., Vs Acit, Central Circle, Sambalpur Lal Building, Kachery Road, Rourkela, Sundergarh, Odisha-769012 Pan No. :Aabcb 3593 P & आयकर अऩीऱ (तऱाशियाां और अशिग्रहण)/It(Ss)A Nos.34 To 39/Ctk/2022 & आयकर अऩीऱ/Ita No.109/Ctk/2022 (ननधाारण वषा / Assessment Year : 2014-2017 To 2020-2021) M/S Bajrangbali Steel Industries Pvt. Vs Acit, Central Circle, Sambalpur Ltd., Lal Building, Kachery Road, Rourkela, Sundergarh, Odisha-769012 Pan No. :Aabcb 3594 L & आयकर अऩीऱ (तऱाशियाां और अशिग्रहण)/It(Ss)A Nos.40 To 44/Ctk/2022 (ननधाारण वषा / Assessment Year : 2014-2015 To 2018-2019) M/S Bajrangbali Re-Rollers Pvt. Ltd. Vs Acit, Central Circle, Sambalpur Lal Building, Kachery Road, Rourkela, Sundergarh, Odisha-769012 Pan No. :Aaccb 6678 A (अऩीऱाथी /Appellant) (प्रत्यथी / Respondent) .. ननधााररती की ओर से /Assessee By : Shri S.K.Tulsiyan, Advocate With Shri B.K. Tibrewal, Ca & Ms. Nisha Rachh, Ca Shri M.K.Gautam, Pr.Cit(Osd) राजस्व की ओर से /Revenue By : सुनवाई की तारीख / Date Of Hearing : 28/03/2023 घोषणा की तारीख/Date Of Pronouncement : 28/03/2023

For Appellant: Shri S.K.Tulsiyan, Advocate with Shri
Section 133ASection 153ASection 292CSection 69Section 69C

books of account or documents seized or requisitioned, he shall proceed against such person and issue such person a notice and assess or reassess undisclosed income of such other person. However, there is a distinction between the two provisions inasmuch as under section 158BC notice can be issued only where ... books of account or documents seized or requisitioned belong to such person, whereas under Section 158BC if the Assessing Officer is satisfied that any undisclosed income belongs to any person, in respect of whom search was made under section 132 or whose books of account or other documents or assets

A2Z Infra Engineering Limited, Gurgaon vs. DCIT- Central Circle-2, Faridabad

In the result, the appeal of the assessee is allowed

ITA 944/DEL/2019[2013-14]Status: DisposedITAT Delhi28 Mar 2023AY 2013-14

Bench: Shri Pradip Kumar Kedia & Shri Anubhav Sharma

For Appellant: Ms. Ritu Kamal Kishore, CAFor Respondent: Shri P. Praveen Sidharth, CIT-DR
Section 132(4)Section 271A

taxes have been paid. The Assessing Officer while imposing penalty @ 10% only alleged that assessee has failed to substantiate the manner of earning such undisclosed income. 4. Aggrieved by the imposition of penalty, the assessee preferred appeal by the CIT(A). The CIT(A) however declined to entertain the relief ... huge business losses at its disposal there was no warrant to make payment of taxes without it being due. It was contended that the undisclosed income once included in the return of income partakes the character of regular income for the purposes of set off and carry forward of remaining

A2Z Infra Engineering Limited, Gurgaon vs. DCIT- Central Circle-2, Faridabad

In the result, the appeal of the assessee is allowed

ITA 943/DEL/2019[2013-14]Status: DisposedITAT Delhi28 Mar 2023AY 2013-14

Bench: Shri Pradip Kumar Kedia & Shri Anubhav Sharma

For Appellant: Ms. Ritu Kamal KishoreFor Respondent: Shri P. Praveen Sidharth, CIT-DR
Section 132Section 132(4)Section 153ASection 271(1)(c)Section 274

Assessment Year 2009- 10 also,. As per the assessment order, the assessee offered a disclosure of Rs.1,56,00,000/- toward undisclosed income in the statement recorded under Section 132(4) of the Act. Similar to AY 2008-09 supra, the aforesaid amount was included by the assessee ... framed whereby penalty of Rs.53,02,440/- was imposed in I.T.As No.2631/Del/2018 & 811, 812, 939, 940, 941, 942, 943/Del/2019 11 respect of the aforesaid undisclosed income offered on the basis of statement under Section 132(4) of the Act. 13.1. The facts and issue in the present case is identical

Infra Engineers Ltd., Gurgaon vs. DCIT, CC-2, Faridabad

In the result, the appeal of the assessee is allowed

ITA 942/DEL/2019[2012-13]Status: DisposedITAT Delhi28 Mar 2023AY 2012-13

Bench: Shri Pradip Kumar Kedia & Shri Anubhav Sharma

For Appellant: Ms. Ritu Kamal KishoreFor Respondent: Shri P. Praveen Sidharth, CIT-DR
Section 132Section 132(4)Section 153ASection 271(1)(c)Section 274

Assessment Year 2009- 10 also,. As per the assessment order, the assessee offered a disclosure of Rs.1,56,00,000/- toward undisclosed income in the statement recorded under Section 132(4) of the Act. Similar to AY 2008-09 supra, the aforesaid amount was included by the assessee ... framed whereby penalty of Rs.53,02,440/- was imposed in I.T.As No.2631/Del/2018 & 811, 812, 939, 940, 941, 942, 943/Del/2019 11 respect of the aforesaid undisclosed income offered on the basis of statement under Section 132(4) of the Act. 13.1. The facts and issue in the present case is identical

A2Z Infra Engineering Limited, Gurgaon vs. DCIT- Central Circle-2, Faridabad

In the result, the appeal of the assessee is allowed

ITA 941/DEL/2019[2011-12]Status: DisposedITAT Delhi28 Mar 2023AY 2011-12

Bench: Shri Pradip Kumar Kedia & Shri Anubhav Sharma

For Appellant: Ms. Ritu Kamal KishoreFor Respondent: Shri P. Praveen Sidharth, CIT-DR
Section 132Section 132(4)Section 153ASection 271(1)(c)Section 274

Assessment Year 2009- 10 also,. As per the assessment order, the assessee offered a disclosure of Rs.1,56,00,000/- toward undisclosed income in the statement recorded under Section 132(4) of the Act. Similar to AY 2008-09 supra, the aforesaid amount was included by the assessee ... framed whereby penalty of Rs.53,02,440/- was imposed in I.T.As No.2631/Del/2018 & 811, 812, 939, 940, 941, 942, 943/Del/2019 11 respect of the aforesaid undisclosed income offered on the basis of statement under Section 132(4) of the Act. 13.1. The facts and issue in the present case is identical

A2Z Infra Engineering Limited, Gurgaon vs. CCIT- Central Circle-2, Faridabad

In the result, the appeal of the assessee is allowed

ITA 940/DEL/2019[2010-11]Status: DisposedITAT Delhi28 Mar 2023AY 2010-11

Bench: Shri Pradip Kumar Kedia & Shri Anubhav Sharma

For Appellant: Ms. Ritu Kamal KishoreFor Respondent: Shri P. Praveen Sidharth, CIT-DR
Section 132Section 132(4)Section 153ASection 271(1)(c)Section 274

Assessment Year 2009- 10 also,. As per the assessment order, the assessee offered a disclosure of Rs.1,56,00,000/- toward undisclosed income in the statement recorded under Section 132(4) of the Act. Similar to AY 2008-09 supra, the aforesaid amount was included by the assessee ... framed whereby penalty of Rs.53,02,440/- was imposed in I.T.As No.2631/Del/2018 & 811, 812, 939, 940, 941, 942, 943/Del/2019 11 respect of the aforesaid undisclosed income offered on the basis of statement under Section 132(4) of the Act. 13.1. The facts and issue in the present case is identical

A2Z Infra Engineering Limited, Gurgaon vs. DCIT CC-2, Faridabad

In the result, the appeal of the assessee is allowed

ITA 939/DEL/2019[2009-10]Status: DisposedITAT Delhi28 Mar 2023AY 2009-10

Bench: Shri Pradip Kumar Kedia & Shri Anubhav Sharma

For Appellant: Ms. Ritu Kamal KishoreFor Respondent: Shri P. Praveen Sidharth, CIT-DR
Section 132Section 132(4)Section 153ASection 271(1)(c)Section 274

Assessment Year 2009- 10 also,. As per the assessment order, the assessee offered a disclosure of Rs.1,56,00,000/- toward undisclosed income in the statement recorded under Section 132(4) of the Act. Similar to AY 2008-09 supra, the aforesaid amount was included by the assessee ... framed whereby penalty of Rs.53,02,440/- was imposed in I.T.As No.2631/Del/2018 & 811, 812, 939, 940, 941, 942, 943/Del/2019 11 respect of the aforesaid undisclosed income offered on the basis of statement under Section 132(4) of the Act. 13.1. The facts and issue in the present case is identical

DCIT-Central Circle-2, Faridabad vs. A2Z Infra Engineers Ltd., Gurgaon

In the result, the appeal of the assessee is allowed

ITA 812/DEL/2019[2012-13]Status: DisposedITAT Delhi28 Mar 2023AY 2012-13

Bench: Shri Pradip Kumar Kedia & Shri Anubhav Sharma

For Appellant: Ms. Ritu Kamal KishoreFor Respondent: Shri P. Praveen Sidharth, CIT-DR
Section 132Section 132(4)Section 153ASection 271(1)(c)Section 274

Assessment Year 2009- 10 also,. As per the assessment order, the assessee offered a disclosure of Rs.1,56,00,000/- toward undisclosed income in the statement recorded under Section 132(4) of the Act. Similar to AY 2008-09 supra, the aforesaid amount was included by the assessee ... framed whereby penalty of Rs.53,02,440/- was imposed in I.T.As No.2631/Del/2018 & 811, 812, 939, 940, 941, 942, 943/Del/2019 11 respect of the aforesaid undisclosed income offered on the basis of statement under Section 132(4) of the Act. 13.1. The facts and issue in the present case is identical

DCIT CC-2, Faridabad vs. A2Z Maintenance and Engineering Services Ltd., Gurgaon

In the result, the appeal of the assessee is allowed

ITA 811/DEL/2019[2011-12]Status: DisposedITAT Delhi28 Mar 2023AY 2011-12

Bench: Shri Pradip Kumar Kedia & Shri Anubhav Sharma

For Appellant: Ms. Ritu Kamal KishoreFor Respondent: Shri P. Praveen Sidharth, CIT-DR
Section 132Section 132(4)Section 153ASection 271(1)(c)Section 274

Assessment Year 2009- 10 also,. As per the assessment order, the assessee offered a disclosure of Rs.1,56,00,000/- toward undisclosed income in the statement recorded under Section 132(4) of the Act. Similar to AY 2008-09 supra, the aforesaid amount was included by the assessee ... framed whereby penalty of Rs.53,02,440/- was imposed in I.T.As No.2631/Del/2018 & 811, 812, 939, 940, 941, 942, 943/Del/2019 11 respect of the aforesaid undisclosed income offered on the basis of statement under Section 132(4) of the Act. 13.1. The facts and issue in the present case is identical

A2Z Maintenance & Engineering Services Ltd., Gurgaon vs. DCIT, Central Circle-II, Faridabad

In the result, the appeal of the assessee is allowed

ITA 2631/DEL/2018[2008-09]Status: DisposedITAT Delhi28 Mar 2023AY 2008-09

Bench: Shri Pradip Kumar Kedia & Shri Anubhav Sharma

For Appellant: Ms. Ritu Kamal KishoreFor Respondent: Shri P. Praveen Sidharth, CIT-DR
Section 132Section 132(4)Section 153ASection 271(1)(c)Section 274

Assessment Year 2009- 10 also,. As per the assessment order, the assessee offered a disclosure of Rs.1,56,00,000/- toward undisclosed income in the statement recorded under Section 132(4) of the Act. Similar to AY 2008-09 supra, the aforesaid amount was included by the assessee ... framed whereby penalty of Rs.53,02,440/- was imposed in I.T.As No.2631/Del/2018 & 811, 812, 939, 940, 941, 942, 943/Del/2019 11 respect of the aforesaid undisclosed income offered on the basis of statement under Section 132(4) of the Act. 13.1. The facts and issue in the present case is identical

Income Tax Officer, Jaipur vs. Sonal Jain, Jaipur

In the result, the above appeals of the Revenue are dismissed

ITA 29/JPR/2023[2013-14]Status: DisposedITAT Jaipur28 Mar 2023AY 2013-14

Bench: SHRI SANDEEP GOSAIN (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Shri P.C. Parwal, CAFor Respondent: Shri Ajey Malik, CIT-DR fu/kZkfjrh dh vksj ls@
Section 138C

machines during the year under consideration. Thus the AO calculated the undervalued purchase of 12 machines at Rs.7,65,602/- and made addition as undisclosed income in the hands of the assessee for the year under consideration. To this effect, the assessee filed further appeal before CESTAT who decided

Fine Gujranwala Jewellers, New Delhi vs. ITO, Ward-51(3), New Delhi

In the result the appeal of the assessee is allowed

ITA 1540/DEL/2022[2017-18]Status: DisposedITAT Delhi27 Mar 2023AY 2017-18

Bench: Shri Anil Chaturvedi & Shri Yogesh Kumar U.S.

For Appellant: Shri K. Sampath, Advocate
Section 285BSection 68

Patna High court held as under: "It is, in my view, a fundamental principle governing the taxation of any undisclosed income or secreted profits that the income or the profits as such must find sufficient explanation at the hands of the assessee. If the balance at hand on the relevant

Sona Power Private Limited, Raipur vs. Assistant Commissioner of Income Tax, Central-2, Raipur

Appeal of the assessee is allowed for statistical purposes

ITA 15/RPR/2020[2011-12]Status: DisposedITAT Raipur27 Mar 2023AY 2011-12

Bench: Shri Ravish Sood & Shri Arun Khodpiaairet Aria &. / Ita No.15/Rpr/2020 Fauhur_ At / Assessment Year : 2011-12

For Appellant: S/sshri Salil Kapoor, Tarun ChananaFor Respondent: Shri Debashish Lahiri, CIT-DR
Section 143(3)Section 147Section 148Section 68

Income, whether taxable or exempt, has been earned and no expenses have been incurred of revenue nature, there is no question of assessee earning undisclosed income. Thus, addition made is bad in law, against law of natural justice, uncalled for and may kindly be deleted. 5. Ground 5: That

Assistant Commissioner of Income Tax, Central Circle -I, Raipur vs. Lord Buddha Educational Society, Raipur

In the result, the appeals of the revenue ITA Nos

ITA 193/RPR/2019[2017-18]Status: DisposedITAT Raipur27 Mar 2023AY 2017-18

Bench: Shri Ravish Sood, Jm & Shri Arun Khodpia, Am आयकर अऩीऱ सं./Ita Nos.188 To 193/Rpr/2019 (ननधाारण वषा / Assessment Year :2012-2013 To 2017-2018) Acit, Central Circle-1, Raipur(Cg) Vs M/S Lord Buddha Educational Society, M/S Raipur Institute Of Medical Sciences (Rims), Gram Godhi, Bhansoj Road, Office Nh-6, Raipur (Cg) Pan No. :Aaaal 3913 E (अऩीऱाथी /Appellant) (प्रत्यथी / Respondent) ..

For Appellant: Shri R.B.Doshi, CAFor Respondent: Shri Debashish Lahiri, CIT-DR
Section 12ASection 143(3)

initiation of search shall abate whereas with regard to scope of provision of sec 153A that where no incriminating material was found indicating any undisclosed income, no additions or disallowance can be made for that particular year. Reliance has been place on the decision of Hon’ble Delhi High Court ... aforementioned six years in separate 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 153A does not say that additions should be strictly made on the basis of evidence found

Assistant Commissioner of Income Tax, Central Circle -I, Raipur vs. Lord Buddha Educational Society, Raipur

In the result, the appeals of the revenue ITA Nos

ITA 192/RPR/2019[2016-17]Status: DisposedITAT Raipur27 Mar 2023AY 2016-17

Bench: Shri Ravish Sood, Jm & Shri Arun Khodpia, Am आयकर अऩीऱ सं./Ita Nos.188 To 193/Rpr/2019 (ननधाारण वषा / Assessment Year :2012-2013 To 2017-2018) Acit, Central Circle-1, Raipur(Cg) Vs M/S Lord Buddha Educational Society, M/S Raipur Institute Of Medical Sciences (Rims), Gram Godhi, Bhansoj Road, Office Nh-6, Raipur (Cg) Pan No. :Aaaal 3913 E (अऩीऱाथी /Appellant) (प्रत्यथी / Respondent) ..

For Appellant: Shri R.B.Doshi, CAFor Respondent: Shri Debashish Lahiri, CIT-DR
Section 12ASection 143(3)

initiation of search shall abate whereas with regard to scope of provision of sec 153A that where no incriminating material was found indicating any undisclosed income, no additions or disallowance can be made for that particular year. Reliance has been place on the decision of Hon’ble Delhi High Court ... aforementioned six years in separate 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 153A does not say that additions should be strictly made on the basis of evidence found

Assistant Commissioner of Income Tax, Central Circle -I, Raipur vs. Lord Buddha Educational Society, Raipur

In the result, the appeals of the revenue ITA Nos

ITA 191/RPR/2019[2015-16]Status: DisposedITAT Raipur27 Mar 2023AY 2015-16

Bench: Shri Ravish Sood, Jm & Shri Arun Khodpia, Am आयकर अऩीऱ सं./Ita Nos.188 To 193/Rpr/2019 (ननधाारण वषा / Assessment Year :2012-2013 To 2017-2018) Acit, Central Circle-1, Raipur(Cg) Vs M/S Lord Buddha Educational Society, M/S Raipur Institute Of Medical Sciences (Rims), Gram Godhi, Bhansoj Road, Office Nh-6, Raipur (Cg) Pan No. :Aaaal 3913 E (अऩीऱाथी /Appellant) (प्रत्यथी / Respondent) ..

For Appellant: Shri R.B.Doshi, CAFor Respondent: Shri Debashish Lahiri, CIT-DR
Section 12ASection 143(3)

initiation of search shall abate whereas with regard to scope of provision of sec 153A that where no incriminating material was found indicating any undisclosed income, no additions or disallowance can be made for that particular year. Reliance has been place on the decision of Hon’ble Delhi High Court ... aforementioned six years in separate 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 153A does not say that additions should be strictly made on the basis of evidence found

Assistant Commissioner of Income Tax, Central Circle -I, Raipur vs. Lord Buddha Educational Society, Raipur

In the result, the appeals of the revenue ITA Nos

ITA 190/RPR/2019[2014-15]Status: DisposedITAT Raipur27 Mar 2023AY 2014-15

Bench: Shri Ravish Sood, Jm & Shri Arun Khodpia, Am आयकर अऩीऱ सं./Ita Nos.188 To 193/Rpr/2019 (ननधाारण वषा / Assessment Year :2012-2013 To 2017-2018) Acit, Central Circle-1, Raipur(Cg) Vs M/S Lord Buddha Educational Society, M/S Raipur Institute Of Medical Sciences (Rims), Gram Godhi, Bhansoj Road, Office Nh-6, Raipur (Cg) Pan No. :Aaaal 3913 E (अऩीऱाथी /Appellant) (प्रत्यथी / Respondent) ..

For Appellant: Shri R.B.Doshi, CAFor Respondent: Shri Debashish Lahiri, CIT-DR
Section 12ASection 143(3)

initiation of search shall abate whereas with regard to scope of provision of sec 153A that where no incriminating material was found indicating any undisclosed income, no additions or disallowance can be made for that particular year. Reliance has been place on the decision of Hon’ble Delhi High Court ... aforementioned six years in separate 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 153A does not say that additions should be strictly made on the basis of evidence found

Assistant Commissioner of Income Tax, Central Circle -I, Raipur vs. Lord Buddha Educational Society, Raipur

In the result, the appeals of the revenue ITA Nos

ITA 189/RPR/2019[2013-14]Status: DisposedITAT Raipur27 Mar 2023AY 2013-14

Bench: Shri Ravish Sood, Jm & Shri Arun Khodpia, Am आयकर अऩीऱ सं./Ita Nos.188 To 193/Rpr/2019 (ननधाारण वषा / Assessment Year :2012-2013 To 2017-2018) Acit, Central Circle-1, Raipur(Cg) Vs M/S Lord Buddha Educational Society, M/S Raipur Institute Of Medical Sciences (Rims), Gram Godhi, Bhansoj Road, Office Nh-6, Raipur (Cg) Pan No. :Aaaal 3913 E (अऩीऱाथी /Appellant) (प्रत्यथी / Respondent) ..

For Appellant: Shri R.B.Doshi, CAFor Respondent: Shri Debashish Lahiri, CIT-DR
Section 12ASection 143(3)

initiation of search shall abate whereas with regard to scope of provision of sec 153A that where no incriminating material was found indicating any undisclosed income, no additions or disallowance can be made for that particular year. Reliance has been place on the decision of Hon’ble Delhi High Court ... aforementioned six years in separate 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 153A does not say that additions should be strictly made on the basis of evidence found

Assistant Commissioner of Income Tax, Central Circle -I, Raipur vs. Lord Buddha Educational Society, Raipur

In the result, the appeals of the revenue ITA Nos

ITA 188/RPR/2019[2012-13]Status: DisposedITAT Raipur27 Mar 2023AY 2012-13

Bench: Shri Ravish Sood, Jm & Shri Arun Khodpia, Am आयकर अऩीऱ सं./Ita Nos.188 To 193/Rpr/2019 (ननधाारण वषा / Assessment Year :2012-2013 To 2017-2018) Acit, Central Circle-1, Raipur(Cg) Vs M/S Lord Buddha Educational Society, M/S Raipur Institute Of Medical Sciences (Rims), Gram Godhi, Bhansoj Road, Office Nh-6, Raipur (Cg) Pan No. :Aaaal 3913 E (अऩीऱाथी /Appellant) (प्रत्यथी / Respondent) ..

For Appellant: Shri R.B.Doshi, CAFor Respondent: Shri Debashish Lahiri, CIT-DR
Section 12ASection 143(3)

initiation of search shall abate whereas with regard to scope of provision of sec 153A that where no incriminating material was found indicating any undisclosed income, no additions or disallowance can be made for that particular year. Reliance has been place on the decision of Hon’ble Delhi High Court ... aforementioned six years in separate 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 153A does not say that additions should be strictly made on the basis of evidence found