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“surrender of income”

Search & SeizureSection 132(4)Section 132(4)324 judgments

DCIT, CENTRAL CIRCLE-4(3), KOLKATA, KOLKATA vs. BRGD SPONGE & IRON PRIVATE LIMITED , KOLKATA

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

ITA 1966/KOL/2025[2016-17]Status: DisposedITAT Kolkata26 Feb 2026AY 2016-17
Section 115JSection 132(1)Section 139(1)Section 143(1)Section 143(2)Section 147Section 148Section 148ASection 68

summary discloser of\nincome as undisclosed and the department accepted the summary\nsurrender of income and thereafter advance tax for the said surrendered\nof income was also deposited, but thereafter it was contended by the\nassessee that the surrender was made under threat or coercion and that\nno incriminating material

BRGD SPONGE & IRON PVT. LTD.,,KOLKATA vs. DCIT, CENTRAL CIRCLE 4(3),, KOLKATA

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

ITA 1403/KOL/2025[2016-2017]Status: DisposedITAT Kolkata26 Feb 2026AY 2016-2017
Section 115JSection 132(1)Section 139(1)Section 143(1)Section 143(2)Section 147Section 148Section 148ASection 68

summary discloser of\nincome as undisclosed and the department accepted the summary\nsurrender of income and thereafter advance tax for the said surrendered\nof income was also deposited, but thereafter it was contended by the\nassessee that the surrender was made under threat or coercion and that\nno incriminating material

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

details on the part of the Department is a highly arbitrary. The Department cannot make an addition over and above the surrender of income made by the assessee during the course of search & seizure action if the said surrender of income itself is not based on the correct facts

VILAS POLYMER PRIVATE LIMITED,HYDERABAD vs. DCIT, CENTRAL CIRCLE-1(2), HYDERABAD

In the result, all the six appeals i

ITA 1874/HYD/2025[2018-19]Status: DisposedITAT Hyderabad18 Feb 2026AY 2018-19

Bench: Shri Vijay Pal Rao & Shri Manjunatha G.आ.अपी.सं /Ita Nos.1870 To 1875/Hyd/2025 Assessment Years 2014-2015 To 2019-2020 Vilas Polymer Private The Dcit, Limited, Hyderabad. Central Circle-1(2), Vs. Pin – 500 090 Hyderabad – 500 004. Pan Aaacv9854A Telangana. (Appellant) (Respondent) िनधा"रती "ारा /Assessee By: Ca M V Prasad 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

For Appellant: CA M V PrasadFor Respondent: Dr. Narendra Kumar Naik, CIT-
Section 132Section 143(3)Section 148Section 149Section 149(1)(b)Section 151

details on the part of the Department is a highly arbitrary. The Department cannot make an addition over and above the surrender of income made by the assessee during the course of search & seizure action if the said surrender of income itself is not based on the correct facts

VILAS POLYMER PRIVATE LIMITED,HYDERABAD vs. DCIT, CENTRAL CIRCLE-1(2), HYDERABAD, HYDERABAD

In the result, all the six appeals i

ITA 1872/HYD/2025[2016-17]Status: DisposedITAT Hyderabad18 Feb 2026AY 2016-17

Bench: Shri Vijay Pal Rao & Shri Manjunatha G.आ.अपी.सं /Ita Nos.1870 To 1875/Hyd/2025 Assessment Years 2014-2015 To 2019-2020 Vilas Polymer Private The Dcit, Limited, Hyderabad. Central Circle-1(2), Vs. Pin – 500 090 Hyderabad – 500 004. Pan Aaacv9854A Telangana. (Appellant) (Respondent) िनधा"रती "ारा /Assessee By: Ca M V Prasad 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

For Appellant: CA M V PrasadFor Respondent: Dr. Narendra Kumar Naik, CIT-
Section 132Section 143(3)Section 148Section 149Section 149(1)(b)Section 151

details on the part of the Department is a highly arbitrary. The Department cannot make an addition over and above the surrender of income made by the assessee during the course of search & seizure action if the said surrender of income itself is not based on the correct facts

VILAS POLYMER PRIVATE LIMITED,HYDERABAD vs. DCIT, CENTRAL CIRCLE-1(2), HYDERABAD

In the result, all the six appeals i

ITA 1870/HYD/2025[2014-15]Status: DisposedITAT Hyderabad18 Feb 2026AY 2014-15

Bench: Shri Vijay Pal Rao & Shri Manjunatha G.आ.अपी.सं /Ita Nos.1870 To 1875/Hyd/2025 Assessment Years 2014-2015 To 2019-2020 Vilas Polymer Private The Dcit, Limited, Hyderabad. Central Circle-1(2), Vs. Pin – 500 090 Hyderabad – 500 004. Pan Aaacv9854A Telangana. (Appellant) (Respondent) िनधा"रती "ारा /Assessee By: Ca M V Prasad 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

For Appellant: CA M V PrasadFor Respondent: Dr. Narendra Kumar Naik, CIT-
Section 132Section 143(3)Section 148Section 149Section 149(1)(b)Section 151

details on the part of the Department is a highly arbitrary. The Department cannot make an addition over and above the surrender of income made by the assessee during the course of search & seizure action if the said surrender of income itself is not based on the correct facts

SANGEETA GOLCHHA, RAIPUR,RAIPUR vs. ITO-4(1), RAIPUR, RAIPUR

In the result, appeal of the assessee is allowed

ITA 788/RPR/2025[2014-15]Status: DisposedITAT Raipur17 Feb 2026AY 2014-15

Bench: Shri Partha Sarathi Chaudhuryआयकर अपील सं./Ita No.788/Rpr/2025 "नधा"रण वष" /Assessment Year : 2014-15 Sangeeta Golchha 9/532, Behind Mahavir Bhawan, Budhapara, Raipur-492 001 (C.G.) Pan: Adcpg6259Q

For Appellant: Shri R.B Doshi, CAFor Respondent: Dr. Priyanka Patel, Sr. DR
Section 10(38)Section 271(1)(c)

dropped as the entire amount arising out of long term capital gain has been offered for taxation is not acceptable. The surrender of income in this case was not voluntary because the offer of surrender was made after the detection made by the 3 Sangeeta Golchha ... factual background, the A.O levied penalty u/s. 271(1)(c) of the Act for furnishing inaccurate particulars of income on the ground that surrendering of income by the assessee and full and true disclosure of such income was not done by the assessee voluntarily and it was surrendered only after

SACHIN,DELHI vs. ACIT, CENTRAL CIRCLE-20, NEW DELHI

In the result, the assessee’s appeal stand dismissed

ITA 1678/DEL/2023[2019-20]Status: DisposedITAT Delhi06 Feb 2026AY 2019-20

Bench: Shri Mahavir Singh & Shri Krinwant Sahaysachin, Vs. Acit, Cc-20, House No. 28R, Gali No. 6A, New Delhi Swatantra Nagar, Narela, New Delhi – 110 044 (Pan:Dlrps3290H) (Appellant) (Respondent) Appellant By : Shri Varun Gupta, Ca Respondent By : Shri Mahesh Kumar, Cit(Dr)

For Appellant: Shri Varun Gupta, CAFor Respondent: Shri Mahesh Kumar, CIT(DR)
Section 143(3)Section 153ASection 69A

business to start a new business at Naya Bazar, Delhi. The assessee’s case is not a voluntarily disclosure or voluntarily surrender of income and disclosed the unexplained cash to the department, hence, in view of section 69A was rightly held by the lower authorities that assessee has failed

M/S COAL INDIA LTD.,KOLKATA vs. DCIT, CIR-5(1), , KOLKATA

ITA 1407/KOL/2019[2014-15]Status: DisposedITAT Kolkata20 Jan 2026AY 2014-15
Section 115J

{"clean_text": "IN THE INCOME TAX APPELLATE TRIBUNAL KOLKATA ‘C’ BENCH, KOLKATA\nBefore\nSHRI PRADIP KUMAR CHOUBEY, JUDICIAL MEMBER\n

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-25, NEW DELHI, DELHI vs. AVTAR SINGH KOCHAR, HARYANA

The appeal of the assessee is allowed and consequently appeal of the\nrevenue is dismissed

ITA 4438/DEL/2025[2019-20]Status: DisposedITAT Delhi09 Jan 2026AY 2019-20
For Appellant: \nSh. MayankPatawari, AdvFor Respondent: \nSh. AlashOjha, Adv
Section 143(3)Section 153D

nsearch operation conducted on 06/02/2019 continued for3 days till\n08/02/2019. The statement of the appellant was recorded by the search team\nwherein a surrender of income from hawala operation was made by him. In\nthe statements recorded

AVTAR SINGH KOCHAR,ROHTAK vs. DCIT,CENTRAL CIRCLE-25, DELHI

The appeal of the assessee is allowed and consequently appeal of the\nrevenue is dismissed

ITA 2909/DEL/2025[2019-20]Status: DisposedITAT Delhi09 Jan 2026AY 2019-20
For Appellant: \nSh. MayankPatawari, AdvFor Respondent: \nSh. AlashOjha, Adv
Section 143(3)Section 153D

nsearch operation conducted on 06/02/2019 continued for3 days till\n08/02/2019. The statement of the appellant was recorded by the search team\nwherein a surrender of income from hawala operation was made by him. In\nthe statements recorded

M/S. BMS SALES PVT. LTD., ,PURULIA vs. DCIT, CENTRAL CIRCLE 3(1), , KOLKATA

In the result, the appeal of the assessee is allowed

ITA 1199/KOL/2025[2019-2020]Status: DisposedITAT Kolkata02 Jan 2026AY 2019-2020
Section 115JSection 132Section 132(1)Section 139(1)Section 142(1)Section 143(1)Section 143(2)Section 147Section 148

summary discloser of\nincome as undisclosed and the department accepted the summary\nsurrender of income and thereafter advance tax for the said surrendered\nof income was also deposited, but thereafter it was contended by the\nassessee that the surrender was made under threat or coercion and that\nno incriminating material

DEVEN CHAUDHRY,MATHURA vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-1(3)(1), MATHURA

In the result, appeal filed by the assessee is allowed

ITA 8/AGR/2025[2017-18]Status: DisposedITAT Agra29 Dec 2025AY 2017-18
Section 115BSection 131Section 143(2)Section 69A

oath in\ndetailed manner that infact a survey was conducted by Income Tax\nDepartment on the assessee during A.Y. 2014-15 and assessee surrendered\nan income of Rs.1,30,00,000/- disclosed at the time of survey and the same\nwas received in cash which was earlier given for purchase ... record by the assessee.\n14. The ratio of the above decision squarely applies to the assessee's case. Here\ntoo, the assessee had surrendered an income of ₹1,30,00,000/- during survey\nin A.Y. 2014-15, on which due Income Tax was paid which was accepted by\nthe Department

INCOME TAX OFFICER, MORBI vs. MAHENDRAKUMAR BHAGVANDAS RANPURA, MORBI

ITA 251/RJT/2024[2017-18]Status: DisposedITAT Rajkot08 Dec 2025AY 2017-18
For Appellant: Shri Abhimanyu Singh Yadav, Ld. Sr. DRFor Respondent: Shri D. M. Rindani, Ld. AR
Section 115BSection 143(3)Section 68

impugned income would, therefore, be at 30%, i.e., the rate specified in sec.\n115BBE as on 30/11/2016, the date of the surrender of income per statement u/s133A (PB-1,\npgs.35-44). This, it may be noted, is also consistent with our view that the income is liable to\nbe assessed

KRYPTON DISTRIBUTORS LLP (EARLIER KNOWN AS KRYPTON DISTRIBUTORS PVT. LTD.,),KOLKATA vs. ITO, WARD 12(1),, KOLKATA

In the result, the appeal of the assessee is allowed

ITA 1733/KOL/2025[2013-2014]Status: DisposedITAT Kolkata02 Dec 2025AY 2013-2014

Bench: Shri Rajesh Kumar, Am & Shri Pradip Kumar Choubey, Jm Krypton Distributors Llp (Earlier Known As Krypton Ito, Ward 12(1), Distributors P. Ltd.) Aaykar Bhawan, P-7, Flat No.1A, 1, Abdul Rasul Chowringhee Square, Vs. Avenue, Kalighat, Kolkata-700069, West Bengal Kolkata-700026, West Bengal (Appellant) (Respondent) Pan No. Aadck5298G Assessee By : Shri Manoj Katuruka, Ar Revenue By : Shri Pankaj Pandey, Dr Date Of Hearing: 13.11.2025 Date Of Pronouncement: 02.12.2025

For Appellant: Shri Manoj Katuruka, ARFor Respondent: Shri Pankaj Pandey, DR
Section 139(1)Section 147Section 148Section 68

offered a summary discloser of income as undisclosed and the department accepted the summary Krypton Distributors LLP ; A.Y. 2013-14 surrender of income and thereafter advance tax for the said surrendered of income was also deposited, but thereafter it was contended by the assessee that the surrender was made under

ACIT CC 2(3) AHMEDABAD, AHMEDABAD vs. AISHA DHIRAJ GOGIA, AHMEDABAD

In the result: 50. To summarize the final outcome:

ITA 1673/AHD/2024[2018-19]Status: DisposedITAT Ahmedabad28 Nov 2025AY 2018-19

Bench: Shri Sanjay Garg & Shri Narendra Prasad Sinha["ी संजय गग", "ाियक सद" एवं "ी नरे" साद िस!ा, लेखा सद" के सम#।]

search and seizure action u/s 132 of the Act, offered a summary discloser of income as undisclosed and the department accepted the summary surrender of income and thereafter advance tax for the said surrendered of income was also deposited, but thereafter it was contended by the assessee that the surrender

PUSA NANDA KUMAR,HYDERABAD vs. DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE3-(1), HYDERABAD

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

ITA 154/HYD/2021[2007-08]Status: DisposedITAT Hyderabad28 Nov 2025AY 2007-08

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.154/Hyd/2021 (िनधा"रण वष"/Assessment Year 2007-2008) Sri Pusa Nanda Kumar, The Dcit, Hyderabad - 500001. Central Circle-3(1), Vs. Hyderabad – 500 004. Pan Acupp6100E (Appellant) (Respondent) िनधा"रती "ारा /Assessee By: Ca P Murali Mohan Rao राज" व "ारा /Revenue By: Ms U Mini Chandran, Cit-Dr

For Appellant: CA P Murali Mohan RaoFor Respondent: MS U Mini Chandran, CIT-DR
Section 131Section 153ASection 50CSection 68

action and the statement of the assessee was recorded u/sec.131 of the Act and submitted that the assessee was forced to admit and surrender the income on account of sale of the land in question, whereas the assessee was only performing his part as a Managing Director of M/s. Pusala ... arising from the sale of land in question as short term capital gain and also surrendered the same to tax. Apart from the surrender of income arising from sale of land in question the assessee has also surrendered a sum of Rs.12 crores and also offered both these incomes

FLINT POWER TOOLS(P) LTD,GURUGRAM vs. ACIT,CENTRAL, CIRCLE-1, FARIDABAD

In the result, Appeal of the Assessee is allowed

ITA 2425/DEL/2025[2021-22]Status: DisposedITAT Delhi26 Nov 2025AY 2021-22

Bench: Yogesh Kumar U.S. & Shri Manish Agarwalm/S Flint Power Tools (P) Ltd. Vs Assistant Commissioner Of B-4, Sushant Lok Phase-1 Income Tax, Central Circle- Gurugram, Haryana, India- Faridabad 1, 122009 Pan: Aadcn0078K Appellant Respondent Assessee By Sh. Lalit Mohan, Ca & Sh. Ankit Kumar, Adv Revenue By Ms. Pooja Swaroop, Cit (Dr) Date Of Hearing 17/11/2025 Date Of Pronouncement 26/11/2025 Order

Section 132(4)Section 143(3)Section 148ASection 40A(2)(b)

para 37 of the order impugned herein: “37. We further find from the order of the ld. CIT(A) that there was no surrender of income for the impugned assessment Flint Power Tools (P) Ltd Vs.ACIT year and the surrender was only for the assessment year 2008-09 which

DEPUTY COMMISSIONER OF INCOME TAX-(1), RAIPUR, RAIPUR vs. AJAY GOLECHAA, RAIPUR

In the result, appeal of the Revenue is dismissed

ITA 454/RPR/2025[2014-15]Status: DisposedITAT Raipur20 Nov 2025AY 2014-15

Bench: Shri Partha Sarathi Chaudhury & Shri Arun Khodpiaआयकर अपील सं. / Ita No.454/Rpr/2025 "नधा"रण वष" / Assessment Year : 2014-15 The Deputy Commissioner Of Income Tax-1(1), Raipur (C.G.)

For Appellant: None (Petition filed)For Respondent: Shri Ram Tiwari, CIT-DR
Section 10(38)Section 143(3)Section 271(1)(c)

arising from transactions in penny stock. 2. Whether the Ld. CIT(A) has erred in law and in facts in holding that the surrender of income by the assessee discharges him from the penal consequences under section 271(1)(c) of the Act, without appreciating the fact that the surrender ... dropped as the entire amount arising out of long term capital gain has been offered for taxation is not acceptable. The surrender of income in this case was not voluntary because the offer of surrender was made after the detection made by the Assessing Officer. Had it been the intention

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-4(3), KOLKATA, KOLKATA vs. SHREE RAMCHANDRA INGOT INDIA PRIVATE LIMITED , KOLKATA

In the result, all six appeals of the assessee are allowed and all six\nappeals of the revenue are dismissed

ITA 1556/KOL/2025[2021-22]Status: DisposedITAT Kolkata19 Nov 2025AY 2021-22
Section 115JSection 132Section 139(1)Section 147Section 148

search and seizure action\nu/s 132 of the Act, offered a summary discloser of\nincome as undisclosed and the department accepted\nthe summary surrender of income and thereafter\nadvance tax for the said surrendered of income was\nalso deposited, but thereafter it was contended by the\nassessee that the surrender

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