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“third party information”

Search & SeizureSection 133(6)Section 133(6)322 judgments

BALWANT LAXMANJI PUROHIT,MUMBAI vs. DCIT CENTRAL CIRCLE 4(2), MUMBAI

In the result, all the three appeal

ITA 8454/MUM/2025[2019-2020]Status: DisposedITAT Mumbai12 Mar 2026AY 2019-2020

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal ()

For Appellant: Mr. Arun Kanti Datta, CIT-DRFor Respondent: Mr. Bharat Kumar
Section 153CSection 250

Odeon Builders Pvt. ltd. (418ITR 315), it was held that the ‘addition/disallowance made solely on third part the ‘addition/disallowance made solely on third party information without y information without subjecting it to further scrutiny and denying the opportunity of cross examination subjecting it to further scrutiny and denying the opportunity

BALWANT LAXMANJI PUROHIT,MUMBAI vs. DCIT CENTRAL CIRCLE 4(2), MUMBAI

In the result, all the three appeal

ITA 8453/MUM/2025[2018-2019]Status: DisposedITAT Mumbai12 Mar 2026AY 2018-2019

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal ()

For Appellant: Mr. Arun Kanti Datta, CIT-DRFor Respondent: Mr. Bharat Kumar
Section 153CSection 250

Odeon Builders Pvt. ltd. (418ITR 315), it was held that the ‘addition/disallowance made solely on third part the ‘addition/disallowance made solely on third party information without y information without subjecting it to further scrutiny and denying the opportunity of cross examination subjecting it to further scrutiny and denying the opportunity

BALWANT LAXMANJI PUROHIT,MUMBAI vs. DCIT CENTRAL CIRCLE 4(2), MUMBAI

In the result, all the three appeal

ITA 8452/MUM/2025[2017-2018]Status: DisposedITAT Mumbai12 Mar 2026AY 2017-2018

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal ()

For Appellant: Mr. Arun Kanti Datta, CIT-DRFor Respondent: Mr. Bharat Kumar
Section 153CSection 250

Odeon Builders Pvt. ltd. (418ITR 315), it was held that the ‘addition/disallowance made solely on third part the ‘addition/disallowance made solely on third party information without y information without subjecting it to further scrutiny and denying the opportunity of cross examination subjecting it to further scrutiny and denying the opportunity

GANESHARAM GALBARAM MALI ,MUMBAI vs. DCIT, CENTRAL CIRCLE 4(2), MUMBAI

In the result the appeals of the assessee bearing ITA No

ITA 8349/MUM/2025[2017-18]Status: DisposedITAT Mumbai12 Mar 2026AY 2017-18
Section 132Section 153CSection 250Section 69Section 69C

nullity'.\n20.In the case of CIT Vs. Odeon Builders Pvt. Itd. (418ITR 315), it was held that the\n'addition/disallowance made solely on third party information without subjecting it to further\nscrutiny and denying the opportunity of cross examination of the third party renders the\naddition/disallowance

GANESHARAM GALBARAM MALI ,MUMBAI vs. DCIT CENTRAL CIRCLE 4(2), MUMBAI

In the result the appeals of the assessee bearing ITA No

ITA 8348/MUM/2025[2018-19]Status: DisposedITAT Mumbai12 Mar 2026AY 2018-19

Bench: Us.

For Appellant: Shri Bharat Kumar, CAFor Respondent: Shri Arun Kanti Datta (CIT DR)
Section 132Section 132(4)Section 153CSection 250Section 69C

nullity'. 20.In the case of CIT Vs. Odeon Builders Pvt. Itd. (418ITR 315), it was held that the 'addition/disallowance made solely on third party information without subjecting it to further scrutiny and denying the opportunity of cross examination of the third party renders the addition/disallowance

GANESHARAM GALBARAM MALI ,MUMBAI vs. DCIT CENTRAL CIRCLE 4(2), MUMBAI

In the result the appeals of the assessee bearing ITA No

ITA 8347/MUM/2025[2019-20]Status: DisposedITAT Mumbai12 Mar 2026AY 2019-20

Bench: Us.

For Appellant: Shri Bharat Kumar, CAFor Respondent: Shri Arun Kanti Datta (CIT DR)
Section 132Section 132(4)Section 153CSection 250Section 69C

nullity'. 20.In the case of CIT Vs. Odeon Builders Pvt. Itd. (418ITR 315), it was held that the 'addition/disallowance made solely on third party information without subjecting it to further scrutiny and denying the opportunity of cross examination of the third party renders the addition/disallowance

ATUL KUMAR GARG,GHAZIABAD vs. LD. ASSESSING OFFICER, FACELESS, DELHI

In the result, the appeal filed by the Assessee is allowed for statistical purposes

ITA 5470/DEL/2025[2022-23]Status: DisposedITAT Delhi11 Mar 2026AY 2022-23

Bench: Shri S. Rifaur Rahman & Shri Vimal Kumaratul Kumar Garg, Ld. Assessing Officer, B K Kapur & Co., Faceless, Delhi. 17, Navyug Market, Vs. Ghaziabad, 201001 Uttar Pradesh. Pan-Akzpk4529K (Appellant) (Respondent) Assessee By None Department By Ms. Harpreet Kaur Hansra, Sr. Dr Date Of Hearing 20.01.2026 Date Of Pronouncement 11.03.2026 O R D E R Per Vimal Kumar, Jm: The Appeal Filed By The Assessee Is Against Order Dated 04.07.2025 Of The Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre, Delhi [Hereinafter Referred To As ‘The Ld. Cit(A)’] Passed U/S 250 Of The Income Tax Act, 1961, [Hereinafter Referred To As ‘The Act’] Arising Out Of Assessment Order Dated 13.02.2024 Of The Assessment Unit Passed U/S 144B R.W.S 14B Of The Act For Assessment Year 2022-23. 2. Brief Facts Of The Case Are That The Assessee Is Running The Wholesale & Retail Trade Of Ghee, Oil & Such Other Products Under The Sole Proprietorship Business Under The Trade Name (Sole Proprietorship) Of M/S Atul Trading Co. During The Year Atul Kumar Garg Vs. Assessing Officer

Section 142(1)Section 143(2)Section 144BSection 250Section 69C

erred in law in confirming the addition made by the Ld. AO has grossly erred in law by solely relying on third party information that too without providing any opportunity for cross examination on request of the assessee. 4. That having regard to the facts and circumstances of the case ... erred in law and on facts in upholding the action of Ld. A.O. by solely relying on third party information and made addition u/s 69C for Rs. 2,11,08,536/- entirely based on surmises, presumptions and conjectures that too without providing any opportunity for verification to meet the ends

BHAGAWATI M JAIN,DOMBIVALI vs. WARD 3(1), KALYAN

In the result, appeal of the assessee is allowed

ITA 2408/MUM/2025[2018-2019]Status: DisposedITAT Mumbai10 Mar 2026AY 2018-2019

Bench: Shri Pawan Singh & Shri Girish Agrawalassessment Year: 2018-19 Bhagawati M Jain Income Tax Officer C-22, Bhanu Chs, Ward 3(1), Bhanu Nagar, Dombivali East, 2Nd Floor, Rani Mansion, Vs. Kalyan - 421201 Kalyan-Murbad Rd, Maharashtra Kalyan-Dombivali, Maharashtra, 421301 (Pan: Aatpj1123G) (Appellant) (Respondent) Present For: Assessee : Shri Viraj Mehta, Ca Revenue : Shri Aditya Rai, Sr. Dr Date Of Hearing : 22.12.2025 Date Of Pronouncement : 10.03.2026 O R D E R Per Girish Agrawal: This Appeal Filed By The Assessee Is Against The Order Of National Faceless Appeal Centre (Nfac), Delhi, Vide Order No. Itba/Nfac/S/250/2024-25/1073449956(1), Dated 19.02.2025, Passed Against The Assessment Order By Assessing Officer, National Faceless Assessment Centre, Delhi, U/S. 147 R.W.S.144B Of The Income- Tax Act (Hereinafter Referred To As The “Act”), Dated 26.02.2024, For Assessment Year 2018-19. 2. Grounds Taken By Assessee Are Reproduced As Under:

For Appellant: Shri Viraj Mehta, CAFor Respondent: Shri Aditya Rai, Sr. DR
Section 132Section 139(1)Section 147Section 148Section 148ASection 151Section 153CSection 69B

decision in the case of CIT vs. ODEON Builders (P) Limited 418 ITR 315, wherein it is held that addition/disallowance made solely on third party information without subjecting it to further scrutiny and denying the opportunity of cross examination of the third party, renders the addition/disallowance

ABDULLATIF IBRAHIM BADARPURA,MUMBAI vs. DCIT CENTRAL CIRCLE 4(2), MUMBAI

ITA 8407/MUM/2025[2018-2019]Status: DisposedITAT Mumbai27 Feb 2026AY 2018-2019

Bench: Shri Narender Kumar Choudhry & Shri Jagadish

Section 132Section 153Section 250

nullity‟. 20.In the case of CIT Vs. Odeon Builders Pvt. ltd. (418ITR 315), it was held that the „addition/disallowance made solely on third party information without subjecting it to further scrutiny and denying the opportunity of cross examination of the third 20 party renders the addition/disallowance

ABDULLATIF IBRAHIM BADARPURA,MUMBAI vs. DCIT CENTRAL CIRCLE 4(2), MUMBAI

ITA 8406/MUM/2025[2017-2018]Status: DisposedITAT Mumbai27 Feb 2026AY 2017-2018

Bench: Shri Narender Kumar Choudhry & Shri Jagadish

Section 132Section 153Section 250

nullity‟. 20.In the case of CIT Vs. Odeon Builders Pvt. ltd. (418ITR 315), it was held that the „addition/disallowance made solely on third party information without subjecting it to further scrutiny and denying the opportunity of cross examination of the third 20 party renders the addition/disallowance

ASHOK HANJAJI MALI,MUMBAI vs. THE ASSISTANT COMMISSIONER OF INCOME TAX,CENTRAL CIRCLE 4(2), MUMBAI, MUMBAI

ITA 7804/MUM/2025[2019-2020]Status: DisposedITAT Mumbai27 Feb 2026AY 2019-2020

Bench: Shri Narender Kumar Choudhry & Shri Jagadish

Section 132Section 153Section 250

nullity‟. 20.In the case of CIT Vs. Odeon Builders Pvt. ltd. (418ITR 315), it was held that the „addition/disallowance made solely on third party information without subjecting it to further scrutiny and denying the opportunity of cross examination of the third 20 party renders the addition/disallowance

ASHOK HANJAJI MALI,MUMBAI vs. THE ASSISTANT COMMISSIONER OF INCOME TAX CENTRAL CIRCLE 4(2)MUMBAI, MUMBAI

ITA 7803/MUM/2025[2018-2019]Status: DisposedITAT Mumbai27 Feb 2026AY 2018-2019

Bench: Shri Narender Kumar Choudhry & Shri Jagadish

Section 132Section 153Section 250

nullity‟. 20.In the case of CIT Vs. Odeon Builders Pvt. ltd. (418ITR 315), it was held that the „addition/disallowance made solely on third party information without subjecting it to further scrutiny and denying the opportunity of cross examination of the third 20 party renders the addition/disallowance

JAIN SANJAYKUMAR SOHANRAJ HUF,MUMBAI vs. DCIT CENTRAL CIRCLE, MUMBAI

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

ITA 7114/MUM/2025[2020-21]Status: DisposedITAT Mumbai27 Feb 2026AY 2020-21

Bench: Hon’Ble Shri Sandeep Gosain& Hon’Ble Shri Bijayananda Pruseth

Section 132(4)Section 153CSection 250Section 69

nullity’. 20.In the case of CIT Vs. Odeon Builders Pvt. ltd. (418ITR 315), it was held that the ‘addition/disallowance made solely on third party information without subjecting it to further scrutiny and denying the opportunity of cross examination of the third party renders the addition/disallowance

JAIN SANJAYKUMAR SOHANRAJ HUF ,MUMBAI vs. DCIT, CENTRAL CIRCLE , MUMBAI

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

ITA 7113/MUM/2025[2019-20]Status: DisposedITAT Mumbai27 Feb 2026AY 2019-20

Bench: Hon’Ble Shri Sandeep Gosain& Hon’Ble Shri Bijayananda Pruseth

Section 132(4)Section 153CSection 250Section 69

nullity’. 20.In the case of CIT Vs. Odeon Builders Pvt. ltd. (418ITR 315), it was held that the ‘addition/disallowance made solely on third party information without subjecting it to further scrutiny and denying the opportunity of cross examination of the third party renders the addition/disallowance

VIMALA JITENDRA JAIN ,MUMBAI vs. THE ASST.CIT,CENTRALCIRCLE4(2), MUMBAI

In the result, the appeals filed by the assessee stands\nallowed

ITA 5571/MUM/2025[2020-21]Status: DisposedITAT Mumbai27 Feb 2026AY 2020-21
Section 115BSection 147Section 153Section 153CSection 250Section 69

nullity'.\n20.In the case of CIT Vs. Odeon Builders Pvt. ltd. (418ITR\n315), it was held that the ‘addition/disallowance made solely\non third party information without subjecting it to further\nscrutiny and denying the opportunity of cross examination of\nthe third party renders the addition/disallowance

VIMALA JITENDRA JAIN ,MUMBAI vs. ASST, CIT.CENTRALCIRCLE4(2), MUMBAI

In the result, the appeal filed by the assessee stands\nallowed

ITA 5570/MUM/2025[2019-20]Status: DisposedITAT Mumbai27 Feb 2026AY 2019-20
Section 115BSection 147Section 153Section 153CSection 250Section 69

nullity'.\n20.In the case of CIT Vs. Odeon Builders Pvt. ltd. (418ITR\n315), it was held that the ‘addition/disallowance made solely\non third party information without subjecting it to further\nscrutiny and denying the opportunity of cross examination of\nthe third party renders the addition/disallowance

LAKHPAT TRADING AND INDUSTRYS PVT. LTD.,JODHPUR vs. ACIT, CIRCLE-3, JODHPUR

In the result, the appeal of the assessee is allowed

ITA 600/JODH/2025[2017-18]Status: DisposedITAT Jodhpur26 Feb 2026AY 2017-18

Bench: Dr. Mitha Lal Meena, Hon’Ble & Shri Sudhir Pareek, Hon’Blelakhpat Trading & Acit, Circle-3 Industryspvt. Ltd. Jodhpur G-72/73 79/80, 1St Phase, Boranada, Jodhpur - 342001 Pan No. Aaccl 5668 C Assessee By Shri Rajendra Jain, Advocate & Smt. Raksha Birla, Ca (Physical) Smt. Runi Pal, Cit-Dr (Virtual) Revenue By Date Of Hearing 29.01.2026. Date Of Pronouncement 26.02.2026. Order Dr. Mitha Lal Meena, A.M.: This Appeal Is Filed By Assessee Against The Order Of National Faceless Appeal Centre, Delhi [Hereinafter Referred To As Nfac/ Cit(A)] Dated 26.06.2025 With Respect To Assessment Year 2017-18 Challenging Therein The Rejection Of Its Books Of Accounts U/S 145(3), Estimation Of Income & Reducing Genuine Sales.

Section 115BSection 145(3)Section 68Section 69C

circumstances of the case, the Id AO grossly erred in treating sales made to M/s Milap Enterprises as bogus by relying on the third party information, which was not subjected to any further scrutiny and also not provided the copy of such 3 Asst. Year: 2017-18 information and also ... made by ld AO was not only objectionable to the appellant but also against the principal of natural justice because as admittedly the third party information as provided by other officer had been blindly accepted as genuine by ld AO without any examination by way of carrying out any investigation

ITO-WD-1(2)(1), AHMEDABAD, AHMEDABAD vs. AVS CORPORATION, AHMEDABAD

In the result, all the three appeals of the Revenue stand dismissed

ITA 1627/AHD/2024[2017-18]Status: DisposedITAT Ahmedabad26 Feb 2026AY 2017-18

Bench: Shri Sanjay Garg & Shri Makarand V. Mahadeokar

For Appellant: Ms. Nupur Shah, ARFor Respondent: Shri Alpesh Parmar, CIT-DR &
Section 115BSection 143(1)Section 147Section 148Section 250Section 69A

borrowed satisfaction was bad in law. 5.1. The Ld. CIT(A) further held that the entire addition in this case was based on third party information gathered by the Investigation Wing of the Department and that the assessee had discharged its onus by placing relevant material/explanation on record. The burden ... Investigation Wing and has not done any further enquiry to confirm the information. Thus, the entire disallowance in this case based on third party information gathered by the Investigation Wing of the Department is illegal as held by the Supreme Court in the case of CIT vs. Odeon Builders

ITO-WD-1(2)(1), AHMEDABAD, AHMEDABAD vs. AVS CORPORATION, AHMEDABAD

In the result, all the three appeals of the Revenue stand dismissed

ITA 1621/AHD/2024[2019-20]Status: DisposedITAT Ahmedabad26 Feb 2026AY 2019-20

Bench: Shri Sanjay Garg & Shri Makarand V. Mahadeokar

For Appellant: Ms. Nupur Shah, ARFor Respondent: Shri Alpesh Parmar, CIT-DR &
Section 115BSection 143(1)Section 147Section 148Section 250Section 69A

borrowed satisfaction was bad in law. 5.1. The Ld. CIT(A) further held that the entire addition in this case was based on third party information gathered by the Investigation Wing of the Department and that the assessee had discharged its onus by placing relevant material/explanation on record. The burden ... Investigation Wing and has not done any further enquiry to confirm the information. Thus, the entire disallowance in this case based on third party information gathered by the Investigation Wing of the Department is illegal as held by the Supreme Court in the case of CIT vs. Odeon Builders

ITO-WD-1(2)(1), AHMEDABAD, AHMEDABAD vs. AVS CORPORATION, AHMEDABAD

In the result, all the three appeals of the Revenue stand dismissed

ITA 1620/AHD/2024[2018-19]Status: DisposedITAT Ahmedabad26 Feb 2026AY 2018-19

Bench: Shri Sanjay Garg & Shri Makarand V. Mahadeokar

For Appellant: Ms. Nupur Shah, ARFor Respondent: Shri Alpesh Parmar, CIT-DR &
Section 115BSection 143(1)Section 147Section 148Section 250Section 69A

borrowed satisfaction was bad in law. 5.1. The Ld. CIT(A) further held that the entire addition in this case was based on third party information gathered by the Investigation Wing of the Department and that the assessee had discharged its onus by placing relevant material/explanation on record. The burden ... Investigation Wing and has not done any further enquiry to confirm the information. Thus, the entire disallowance in this case based on third party information gathered by the Investigation Wing of the Department is illegal as held by the Supreme Court in the case of CIT vs. Odeon Builders

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