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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

Trifecta Projects Private Limited, Bengaluru vs. DCIT, Central Circle-2(2), Bangalore

In the result, the appeal filed by the assessee is allowed

ITA 918/BANG/2025[2020-21]Status: DisposedITAT Bangalore05 Dec 2025AY 2020-21

Bench: Shri Prashant Maharishi, Vice – & Shri Soundararajan K.Assessment Year : 2020-21

For Appellant: Shri V. Srinivasan, AdvocateFor Respondent: Shri Subramanian .S, JCIT-DR
Section 132Section 143(1)Section 143(2)Section 153ASection 271ASection 274Section 37Section 40ASection 40A(3)

made u/s. 37[1] of the Act Page 2 of 7 in the assessment proceedings cannot be considered as undisclosed income found at the time of search in order to impose penalty u/s. 271AAB of the Act under the facts and in the circumstances of the appellant's case ... accepted the said claims and paid the tax dues to the department to buy peace. The AO had treated the said disallowances as undisclosed income warranting penalty u/s. 271AAB of the Act. Subsequently, the penalty notice u/s. 274 r.w.s. 271AAB was issued in which the AO had alleged that based

DCIT - 19(1), Mumbai, Piramal Chambers vs. Dishant Deepak Shah, Mumbai

In the result, appeal of the revenue is dismissed

ITA 4281/MUM/2025[2016-17]Status: DisposedITAT Mumbai05 Dec 2025AY 2016-17

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan () Assessment Year: 2016-17

For Appellant: Shri Satyaprakash Singh
Section 10(38)Section 68Section 69C

proceeds of and further addition made on account of sale proceeds of and further addition made on account of sale proceeds of shares as undisclosed income of shares as undisclosed income of assessee under section assessee under section 68 was unjustified. The relevant part of the judgment

Royal Chains Private Limited, Mumbai vs. Deputy Commissioner of Income Tax Central Circle 3(3), Mumbai

In the result, appeal filed by the assessee stands partly allowed

ITA 4260/MUM/2025[2019-20]Status: DisposedITAT Mumbai05 Dec 2025AY 2019-20

Bench: Smt. Beena Pillai () & Smt. Renu Jauhri ()

Section 142(1)Section 143(2)Section 69ASection 80

other hand has vehemently contested the basis of the addition and has made detailed submissions, which are summarized as under: (i) No admission of undisclosed income: It was submitted that Shri Suresh Jain never admitted that the excess stock constituted undisclosed LT.A. No. 4260/Mum/2025 LT.A. No. 4845/Mum/2025 income. He merely ... factually and legally untenable. Firstly, it is not in dispute that Shri Suresh Jain did not admit that the stock difference represented undisclosed income and this fact is clear from the extract of his statement that has been reproduced by the AO in his assessment order. He merely acknowledged

Vaksons Metaplast Pvt Ltd, Delhi vs. PCIT(Central), Delhi

In the result, the appeal, filed by the assessee is partly allowed

ITA 2218/DEL/2025[2019-20]Status: DisposedITAT Delhi05 Dec 2025AY 2019-20

Bench: Shris.Rifaur Rahman & Shri Anubhav Sharma

For Appellant: Smt. Rano Jain, AdvocateFor Respondent: Shri Amit Jain, CIT DR
Section 115BSection 132Section 139Section 143Section 153Section 153CSection 234ASection 263Section 69C

were purchased both on account of purchase. Therefore it cannot be said that the total amount of such bills pertaining to purchase transaction are undisclosed income of the assessee to be taxed under section 68,69A of the Act, as proposed by your goodself in the impugned notice

Vaksons Metaplast Pvt Ltd, Delhi vs. PCIT(Central), Delhi

In the result, the appeal, filed by the assessee is partly allowed

ITA 2217/DEL/2025[2018-19]Status: DisposedITAT Delhi05 Dec 2025AY 2018-19

Bench: Shris.Rifaur Rahman & Shri Anubhav Sharma

For Appellant: Smt. Rano Jain, AdvocateFor Respondent: Shri Amit Jain, CIT DR
Section 115BSection 132Section 139Section 143Section 153Section 153CSection 234ASection 263Section 69C

were purchased both on account of purchase. Therefore it cannot be said that the total amount of such bills pertaining to purchase transaction are undisclosed income of the assessee to be taxed under section 68,69A of the Act, as proposed by your goodself in the impugned notice

Vaksons Metaplast Pvt Ltd, Delhi vs. PCIT(Central), Delhi

In the result, the appeal, filed by the assessee is partly allowed

ITA 2216/DEL/2025[2017-18]Status: DisposedITAT Delhi05 Dec 2025AY 2017-18

Bench: Shris.Rifaur Rahman & Shri Anubhav Sharma

For Appellant: Smt. Rano Jain, AdvocateFor Respondent: Shri Amit Jain, CIT DR
Section 115BSection 132Section 139Section 143Section 153Section 153CSection 234ASection 263Section 69C

were purchased both on account of purchase. Therefore it cannot be said that the total amount of such bills pertaining to purchase transaction are undisclosed income of the assessee to be taxed under section 68,69A of the Act, as proposed by your goodself in the impugned notice

Vimalarjun Trust, Lucknow vs. ACIT, Central Circle-2, Delhi

In the result, the appeal of assessee is allowed

ITA 2094/DEL/2024[2017-18]Status: DisposedITAT Delhi05 Dec 2025AY 2017-18

Bench: Shri S Rifaur Rahman & Shri Vimal Kumarassessment Year 2017-18 Vimalarjun Trust, Vs. Acit, 2/652, Vikram Khand, Gomti Circle-2, Nagar, Lucknow Delhi Uttar Pradesh Pin: 226010 Pan No. Aabtv7815R (Appellant) (Respondent)

For Appellant: Shri Ved Jain, Advs. & Shri PawanFor Respondent: Shri Sanjay Kaushal, CIT DR
Section 133ASection 139Section 142(1)Section 143(1)Section 143(2)Section 153Section 153CSection 250

burden lies on the Department to prove that the impugned document belongs to the assessee and relates to 7 undisclosed income of the assessee. Mere suspicion, howsoever strong, cannot substitute legal proof. This being an unabated assessment, the burden is on Ld. AO to first establish that the document found

ACIT-Circle-2(1)(1), Agra vs. Puneet Agarwal, Agra

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

ITA 338/AGR/2025[2015-16]Status: DisposedITAT Agra04 Dec 2025AY 2015-16

Bench: SHRI S. RIFAUR RAHMAN (Accountant Member), SHRI SUNIL KUMAR SINGH (Judicial Member)

For Appellant: Shri Sudhir Sehgal, AdvocateFor Respondent: Shri Arun Kumar Yadav, CIT DR
Section 132(1)Section 132(4)

purchases of land and the same were not recorded in the regular books of accounts and surrendered the amount of Rs. 40 crores as undisclosed income for F.Y. 2014-2015 in the hand of Sh. Vishwambhar CO Nos.04, 03 & 05/Agr/2025 Dayal for taxation in the capacity of Managing Director ... Rs.45,81,000/- was found, out of which, the assessee admitted during the course of search that a sum of Rs.42 lacs as undisclosed income for Fin. Year 2014-15 and, thus, the said amount of Rs.42 lacs were also surrendered during the course of search and which have been

ACIT, Circle-2(1)(1), Agra vs. Sh. Vishwambhar Dayal Agarwal, Agra

ITA 337/AGR/2025[2015-16]Status: DisposedITAT Agra04 Dec 2025AY 2015-16

Bench: Shri S. Rifaur Rahman & Shri Sunil Kumar Singh

For Appellant: Shri Sudhir Sehgal, AdvocateFor Respondent: Shri Arun Kumar Yadav, CIT DR
Section 132(1)Section 132(4)

purchases of land and the same were not recorded in the regular books of accounts and surrendered the amount of Rs. 40 crores as undisclosed income for F.Y. 2014-2015 in the hand of Sh. Vishwambhar 5 ITA No.337, 330, 336 & 338 &/Agr/2025 CO Nos.04, 03 & 05/Agr/2025 Dayal for taxation ... Rs.45,81,000/- was found, out of which, the assessee admitted during the course of search that a sum of Rs.42 lacs as undisclosed income for Fin. Year 2014-15 and, thus, the said amount of Rs.42 lacs were also surrendered during the course of search and which have been

ACIT-Circel-2(1)(1), Agra vs. Mayank Agrawal, Agra

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

ITA 336/AGR/2025[2015-16]Status: DisposedITAT Agra04 Dec 2025AY 2015-16

Bench: SHRI S. RIFAUR RAHMAN (Accountant Member), SHRI SUNIL KUMAR SINGH (Judicial Member)

For Appellant: Shri Sudhir Sehgal, AdvocateFor Respondent: Shri Arun Kumar Yadav, CIT DR
Section 132(1)Section 132(4)

purchases of land and the same were not recorded in the regular books of accounts and surrendered the amount of Rs. 40 crores as undisclosed income for F.Y. 2014-2015 in the hand of Sh. Vishwambhar CO Nos.04, 03 & 05/Agr/2025 Dayal for taxation in the capacity of Managing Director ... Rs.45,81,000/- was found, out of which, the assessee admitted during the course of search that a sum of Rs.42 lacs as undisclosed income for Fin. Year 2014-15 and, thus, the said amount of Rs.42 lacs were also surrendered during the course of search and which have been

Vishwambhar Dayal Agarwal, Agra vs. Deputy Commissioner of Income Tax, Circle2(1)(1), Agra

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

ITA 330/AGR/2025[2015-16]Status: DisposedITAT Agra04 Dec 2025AY 2015-16

Bench: SHRI S. RIFAUR RAHMAN (Accountant Member), SHRI SUNIL KUMAR SINGH (Judicial Member)

For Appellant: Shri Sudhir Sehgal, AdvocateFor Respondent: Shri Arun Kumar Yadav, CIT DR
Section 132(1)Section 132(4)

purchases of land and the same were not recorded in the regular books of accounts and surrendered the amount of Rs. 40 crores as undisclosed income for F.Y. 2014-2015 in the hand of Sh. Vishwambhar CO Nos.04, 03 & 05/Agr/2025 Dayal for taxation in the capacity of Managing Director ... Rs.45,81,000/- was found, out of which, the assessee admitted during the course of search that a sum of Rs.42 lacs as undisclosed income for Fin. Year 2014-15 and, thus, the said amount of Rs.42 lacs were also surrendered during the course of search and which have been

ACIT, CC, Agra vs. M/S. United Farm Product Private Limited, Agra

In the result, appeal preferred by the revenue is dismissed

ITA 299/AGR/2025[2022-23]Status: DisposedITAT Agra04 Dec 2025AY 2022-23

Bench: Shris.Rifaur Rahman & Shri Sunil Kumar Singhacit, Cc, Vs. M/S. United Farm Product Pvt. Ltd., 2/220, 2Nd Floor, Glory Plaza, Agra. Soor Sadan, M.G. Road, Agra – 282 002 (Agra) (Pan :Aaccu2505M) (Appellant) (Respondent) Assessee By : Shri Sudhir Sehgal, Advocate Shri Deependra Mohan, Ca Revenue By : Shri Arun Kumar Yadav, Cit Dr Date Of Hearing : 13.10.2025 Date Of Order : 04.12.2025 O R D E R Per S. Rifaur Rahman,Am: 1. This Appeal Is Filed By The Revenue Against The Order Of Ld. Commissioner Of Income-Tax (Appeals), Kanpur – 4 Dated 28.03.2025 For Assessment Year2022-23 Raising Following Grounds Of Appeal :- “L. Whether On Facts & Circumstances Of The Case & In Law. The Ld. Cit(A)-Iv. Kanpur Has Erred In Deleting The Addition Of Rs.43,71,37,934/- On Account Of Unexplained Expenditure U/S 69C Of The Act Incurred For Construction Of Plant At Mewat, Haryana, Without Appreciating The Fact That The Assessee Company Itself Has Surrendered Amount Of Rs.41,40,35,700/- & Admitted To Take The Unexplained Expenditure At Rs.43,71,37,934/- Incurred In The 2 Construction Of Said Plant. Hence, The Addition Made By The Ao Is Based On Admittance By The Assessee, Which Is Corroborated By The Incriminating Material Found During The Course Of Search. 2. Whether On Facts & Circumstances Of The Case & In Law, Ld. Cit(A)-Iv. Kanpur Has Erred In Deleting The Addition. Without Appreciating The Facts That The Assessing Officer Has Passed The Assessment Order After Thoroughly Examining & Analysing The Seized Material & Proper Appreciation Of Facts Of Unexplained Expenditure U/S 69C Of The Act.”

For Appellant: Shri Sudhir Sehgal, AdvocateFor Respondent: Shri Arun Kumar Yadav, CIT DR
Section 69C

establishing the preponderance of probability. The Assessing Officer should make diligent efforts to detect the modus operandi and the manner in which the undisclosed income was generated by the assessee. In case it is found that the seized papers, corroborating the fact of generation of undisclosed income, pertain ... instructions 21 from CBDT, as per which the AO should make diligent efforts to detect the modus operandi and the manner in which the undisclosed income was generated by the assessee. There is no room for presumption or multiplication formula. With the above observations, he came to the conclusion that

Chintan Umedsinh Sodha, Jamnagar vs. Income Tax Officer, Ward 1(3), Jamnagar

In the result, appeal filed by the assessee is partly allowed in above terms

ITA 246/RJT/2024[2016-17]Status: DisposedITAT Rajkot04 Dec 2025AY 2016-17

Bench: Dr. Arjun Lal Sainiआयकरअपील सं. /Ita No.246/Rjt/2024 िनधा"रण वष"/Assessment Year : 2016-17 बनाम Chintan Umedsinh Sodha Income Tax Officer “Het” Chitrkutt Society, / Ward – 1(3), Jamnagar Plot No. 21-22, Vs Opp. Khodiyar Co, Jamnagar- 361 006 Gujrat India "ायीलेखासं./जीआइआरसं./Pan/Gir No.: Avgps4814B (अपीलाथ"/Assessee) (""थ"/Respondent)

For Appellant: Shri Vimal Desai, Ld. ARFor Respondent: Shri Abhimanyu Singh Yadav, Ld. Sr. DR
Section 133(6)Section 142(1)Section 143Section 143(2)Section 143(3)Section 250

disclosed in return of income. 5. From the above, the A.O. noticed that the agriculture income is nothing but the assessee's own undisclosed income which is diverted under the guise of agricultural income. Merely furnishing the copy of 7/12, 8-A and income and expenditure account

ACIT, Circle 3, Lucknow vs. Anshuman Singh, Lucknow

In the result, the appeal of Revenue is allowed

ITA 342/LKW/2025[2017-18]Status: DisposedITAT Lucknow04 Dec 2025AY 2017-18

Bench: Shri Kul Bharat & Shri Anadee Nath Misshra

Section 139Section 142Section 142(1)Section 143Section 143(3)Section 144Section 147Section 148

bank account but then such an opinion proceeds on the fallacious assumption that the bank deposits constitute undisclosed income, and overlooks the fact that the sources of deposit need not necessarily be income of the assessee. Of course, it may be desirable, from the point of view of revenue authorities

DCIT CC 2(2) Kolkata, Kolkata vs. Akriti Sales Pvt Ltd, Kolkata

In the result, the appeal of the Revenue is dismissed and CO of the assessee is allowed

ITA 1779/KOL/2025[2015-16]Status: DisposedITAT Kolkata04 Dec 2025AY 2015-16

Bench: Shri Rajesh Kumar, Am & Shripradip Kumar Choubey, Jm Dcit Cc2(2) Kolkata Akriti Sales Pvt. Ltd. Aaykar Bhawan Poorva 34 Indra Kumar Karnani Street, 110 Shanti Pally, Kolkata, Vs. Kolkata-700001, West Bengal Kolkata-700107, West Bengal (Appellant) (Respondent) Pan No. Aagca2765B Co No. 70/Kol/2025 (Ita No. 1779/Kol/2025 For A.Y. 2015-16) Dcit Cc2(2) Kolkata Akriti Sales Pvt. Ltd. Aaykar Bhawan Poorva 34 Indra Kumar Karnani Street, 110 Shanti Pally, Kolkata, Vs. Kolkata-700001, West Bengal Kolkata-700107, West Bengal (Respondent) (Appellant) Assessee By : Shri S.M. Surana, Ar Revenue By : Shri Manas Mondal, Dr Date Of Hearing: 16.10.2025 Date Of Pronouncement: 04.12.2025

For Appellant: Shri S.M. Surana, ARFor Respondent: Shri Manas Mondal, DR
Section 115BSection 133ASection 68

added by the ld. AO u/s 68 of the Act in respect of undisclosed income in the form of cash sales found during the course of survey operation u/s 133A of the Act. 3.1. The facts in brief are that a survey operation u/s 133A of the Act was conducted ... which were accepted by Shri Rajendra Kumar Mourya, the key person of the Arya Group. The Arya Group admitted that the undisclosed income was on account of cash received as advance against the booking of flats in A.Y. 2014-15 and in earlier years in his disclosures before the DDIT

Assisstant Commissioner of Income Tax, Chennai vs. Bannari Amman Sugar Limited, Coimbatore

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

ITA 3361/CHNY/2024[2021]Status: DisposedITAT Chennai04 Dec 2025

Bench: Shri Aby T. Varkey & Shri Jagadish

For Appellant: Mr. R. Vijayarghavan &For Respondent: Mr. Shiva Srinivas CIT
Section 131Section 132Section 132(4)Section 153CSection 250

M/s.Bannari Amman Sugars Ltd. :: 13 :: detected after search and seizure operations are carried out, the AO is required to determine the undisclosed income and in such cases, additions may be based on estimates but in matter of estimation, some amount of latitude is required to be shown ... settled that in cases where material is detected after search and seizure operations are carried out, the Assessing Officer is required to determine the undisclosed income. In such cases additions are generally based on estimates. In matters of estimation some amount of latitude is required to be shown

Assisstant Commissioner of Income Tax, Chennai vs. Bannari Amman Sugar Limited, Coimbatore

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

ITA 3360/CHNY/2024[2019]Status: DisposedITAT Chennai04 Dec 2025

Bench: Shri Aby T. Varkey & Shri Jagadish

For Appellant: Mr. R. Vijayarghavan &For Respondent: Mr. Shiva Srinivas CIT
Section 131Section 132Section 132(4)Section 153CSection 250

M/s.Bannari Amman Sugars Ltd. :: 13 :: detected after search and seizure operations are carried out, the AO is required to determine the undisclosed income and in such cases, additions may be based on estimates but in matter of estimation, some amount of latitude is required to be shown ... settled that in cases where material is detected after search and seizure operations are carried out, the Assessing Officer is required to determine the undisclosed income. In such cases additions are generally based on estimates. In matters of estimation some amount of latitude is required to be shown

Rakesh Jain, Mumbai vs. National Faceless Appeal Centre (NFAC), Delhi

In the result the appeal filed by the assessee stands allowed

ITA 546/MUM/2025[2017-18]Status: DisposedITAT Mumbai04 Dec 2025AY 2017-18

Bench: Shri Sandeep Gosain & Shri Prabhash Shankarι.Τ.Α. No.546/Mum/2025 A.Y: 2017-18 Rakesh Jain Vs Dcit - 26(1) Shop No. 29, 2Nd Floor, Kautilya Bhavan, 126-128, Sheikh Menon Bandra, Mumbai St., Trimurti Estate, Kalbadevi, Mumbai Pan – Aaιρj7359P (Appellant) (Respondent) Assessee By | Shri Vimal Punmiya Revenue By || Shri Annavaran Kosuri, Sr. Dr Date Of Hearing 17.09.2025 Date Of Pronouncement 04.12.2025 Order Per: Shri. Sandeep Gosain, J.M.: The Present Appeal Has Been Filed By The Assessee Challenging The Impugned Order Dt.28.11.2024 Passed Under Section 250 Of The Income Tax Act, 1961 (‘The Act'), By The National Faceless Appeal Centre (Nfac) / Cit(A) For The

Section 115Section 144Section 145Section 156Section 250Section 274Section 68

existing stock were sufficient to explain deposit of cash (obtained from realization of sales) in bank account and could not have been treated as undisclosed income of assessee and accordingly, impugned addition made by Assessing Officer was not justified Held, yes [Paras 10.5, 10.7, 10.9, 10.11 and 10.13] [In favour ... existing stock were sufficient to explain deposit of cash (obtained from realization of sales) in bank account and could not have been treated as undisclosed income of assessee and accordingly, impugned addition made by Assessing Officer was not justified Held, yes [Paras 10.5, 10.7, 10.9, 10.11 and 10.13] [In favour

Gurdeep Singh, Delhi vs. Manoj Kumar Assistant Commissioner of Income Tax, Central Circle -31, New Delhi

Appeal is allowed

ITA 5306/DEL/2025[2021-22]Status: DisposedITAT Delhi04 Dec 2025AY 2021-22

Bench: Sh. Satbeer Singh Godara & Sh. Manish Agarwal

For Appellant: Sh. Rajiv Kumar Jain, CAFor Respondent: Sh. Jitender Singh, CIT-DR
Section 143(3)Section 153C

hearing that both the learned lower authorities have added an amount of Rs.47,00,000/- as the assessee’s on-money representing his undisclosed income; paid for purchase of a property at 3rd Floor, C-94, Nirman Vihar, Delhi to the extent of ½ share. There is no dispute between

Sh. Vivek Gupta, Haryana vs. ACIT/DCIT, Haryana

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

ITA 5037/DEL/2025[2018-19]Status: DisposedITAT Delhi04 Dec 2025AY 2018-19

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal[Assessment Year : 2018-19] Shri Vivek Gupta Vs Acit/Dcit C-5/2A, Opp. C. C. Colony Central Circle Rana Pratap Bagh, North Delhi Karnal Delhi-110007 Pan-Aappg4029A Appellant Respondent Appellant By Shri Ved Jain, Adv. & Ms. Uma Upadhyay, Ca Respondent By Ms. Amisha S.Gupt, Cit Dr Date Of Hearing 04.12.2025 Date Of Pronouncement 04.12.2025 Order Per Manish Agarwal, Am : The Present Appeal Is Filed By Assessee Against The Order Dated 29.07.2025 By Ld. Commissioner Of Income Tax (A)-3, Gurgaon [“Ld.Cit(A)”] In Appeal No.10453/2019-20 Passed U/S 250 Of The Income Tax Act, 1961 [“The Act”] Arising Out Of Assessment Order Dated 29.12.2019 Passed U/S 143(3) R.W.S. 153B(1)(B) Of The Act Pertaining To Assessment Year 2018-19. 2. Brief Facts Of The Case Are That A Search & Seizure Operation U/S 132 Were Carried Out At The Business Premises Of M/S. Oswal Group Of Cases, Karnal & Residential Premises Of Its Members On 22.01.2018. The Case Of The Assessee Was Also Covered U/S 132 Of The Act. Assessee Filed His Return Of Income On 28.07.2018 Declaring Total Income Of Inr 13,36,300/-. Thereafter, Statutory Notice U/S 143(2) Of The Act Was Issued On 23.04.2019 Followed By Notices U/S 142(1) Of The Act Alongwith Questionnaire Issued From Time To Time. In Response To Above, Assessee Filed Replies. Thereafter, The Ao Passed The Assessment Order U/S 143(3) R.W.S. 153B(1)(B) Of The Act Dated 29.12.2019 Assessing Total Income Of The Assessee At Inr 81,59,730/-.

Section 115BSection 132Section 142(1)Section 143(2)Section 143(3)Section 153DSection 250Section 69Section 69A

addition of Rs. 1,67,220/- made by the AO on account of cash found during the course of search treating the same as undisclosed income under section 69A r.w.s. 115BBE of the Income Tax Act, 1961. (ii) That the abovesaid addition has been confirmed ignoring the submissions and explanations