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“estimation of income”

Assessment ProceduresSection 145Section 1453,061 judgments

The decision most relied on for estimation of income is CIT v. Simit P. Sheth (356 ITR 451), cited in 1,465 judgments on BharatTax.

Leading authorities on estimation of income

CIT v. Simit P. Sheth
356 ITR 451 · 2013 · High Court
1,465
citing judgments

When purchases are unproved or presumed to be from the grey market, the entire amount of such purchases should not be disallowed; instead, income can be estimated by applying a reasonable gross profit rate to the unaccounted sales or turnover, especially in assessments arising from search proceedings involving seized documents.

Rotork Controls India Pvt. Ltd. v. CIT
314 ITR 62 · 2009 · Supreme Court
739
citing judgments

A provision for expenses, such as warranty, is a deductible liability for income tax purposes if it constitutes a present obligation arising from past events, and a reliable estimate of the amount of obligation is possible.

Sanjay Oilcake Industries v. CIT
316 ITR 274 · 2009 · High Court
460
citing judgments

In cases of alleged bogus or unverifiable purchases, rather than disallowing the entire purchase value, a reasonable profit element or a proportionate percentage of the purchases should be added back to the assessee's income.

Kachwala Gems v. JCIT
288 ITR 10 · 2007 · Supreme Court
332
citing judgments

In a best judgment assessment, some guesswork is inherent, but the estimate must be fair and not arbitrary. Books of account can be rejected under Section 145(3) if the assessee fails to substantiate entries or prove the genuineness of transactions, leading to estimation of income.

CIT v. Devi Prasad Vishwanath Prasad
72 ITR 194 · 1969 · Supreme Court
272
citing judgments

If there is an unexplained cash credit, the Assessing Officer can treat it as the assessee's income, even when the income is finalized on an estimation basis, without proving its specific source. The onus then shifts to the assessee to prove that the income represented by the cash credit has already been taxed.

Commissioner of Sales Tax v. H.M. Esufali H.M. Abdulali
90 ITR 271 · 1973 · Supreme Court
232
citing judgments

The Supreme Court established principles for best judgment assessments, stating that some guesswork is inevitable but the assessment must be bona fide, rational, and free from bias or capriciousness. An appellate authority cannot substitute its judgment for that of the Assessing Officer unless the AO's assessment is shown to be biased, irrational, vindictive, or capricious, especially when the assessee fails to provide proper accounts or counter-evidence.

CIT v. Balchand Ajit Kumar
263 ITR 610 · 2003 · High Court
212
citing judgments

When making an addition for unaccounted receipts, on-money, or non-genuine purchases/sales, the addition should be restricted to the estimated profit element embedded in such transactions, rather than the entire gross amount, particularly when evidence of corresponding expenditure is incomplete. This estimation often involves applying a net profit rate.

Harigopal Singh v. CIT
258 ITR 85 · 2002 · High Court
203
citing judgments

Penalty under section 271(1)(c) cannot be levied when an addition to income is made on an estimated basis without concrete evidence of concealment or furnishing inaccurate particulars of income. The provisions of section 271(1)(c) are not attracted to cases where income is assessed on an estimate basis.

Judgments citing estimation of income

Prem Prakash Agarwal, Naya Bazar Ajmer vs. DCIT Central Circle Ajmer, Jaipur Road Ajmer

In the result, three appeals of the assessee are allowed

ITA 758/JPR/2023[2018-19]Status: DisposedITAT Jaipur09 Feb 2024AY 2018-19

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

For Appellant: Sh. C. M. Agarwal (CA)For Respondent: Sh. Ajay Malik (CIT)
Section 132Section 153ASection 271ASection 274

happy with the disclosure given by the assessee and did not verify the factual position with the books of accounts and estimation of income and bring the evidence to unearth or quantify the said income as undisclosed income. Neither the A.O. nor the investigation wing linked the sales recorded

Vishwanathareddy Chennareddy, Bangalore vs. Income-Tax Officer, Ward-2(2)(7), Bengaluru

In the result, appeal of the assessee is partly allowed for statistical purposes

ITA 900/BANG/2023[2017-18]Status: DisposedITAT Bangalore01 Feb 2024AY 2017-18

Bench: SHRI CHANDRA POOJARI (Accountant Member), SMT. BEENA PILLAI (Judicial Member)

For Appellant: Shri Hemasundara Rao P., A.RFor Respondent: Shri Subramanian S., D.R
Section 250Section 251Section 68Section 69A

bank account. Subsequently, the contention was raised before the learned CIT (Appeals) wherein he stated that the rejection of books and estimation of income does not make any difference to the income returned by the Assessee and remains only a technical/procedural aspect. 5.9 Further, he submitted that the learned

ITO-1(2)(1), Mumbai vs. M/S Koyana Glass Works Pvt Ltd, Mumbai

In the result, appeal of the revenue stands dismissed

ITA 2383/MUM/2023[2000-01]Status: DisposedITAT Mumbai29 Jan 2024AY 2000-01

Bench: Shri Aby T. Varkey, Jm & Shri S Rifuar Rahman, Am आयकर अपील सं/ I.T.A. No 2383/Mum/2023 (निर्धारण वर्ा / Assessment Year: 2000-01) Ito, 1(2)(1), Mumbai बिधम / M/S Koyna Glass Works Room No. 536, 5Th Floor, Pvt. Ltd. Vs. Aayakar Bhavan, M K 2C, Lawrence & Mayo Road, Mumbai-400020 House, Dr. D. N. Road, Fort, Mumbai-400001 स्थधयी लेखध सं/.जीआइआर सं/.Pan/Gir No. : Aacck7983K (अपीलार्थी / Appellant) (प्रत्यर्थी / Respondent) ..

For Appellant: Shri D. D. AnjariaFor Respondent: Shri P. D. Chougule (Sr. AR)
Section 144

only grievance of the Revenue is against the action of the Ld. CIT(A) reducing the estimation of income from 10% of the annual export as computed by the AO to 0.5% of it. 3. At the outset, we are informed that this is the third (3rd) round of litigation ... other alternative but to pass the best judgement assessment u/s 144 of the Income Tax Act, 1961 (hereinafter “the Act”) estimating the income at Rs. 6,29,84,437/- vide order dated 21.03.2006 u/s 144 of the Act [hereinafter the first assessment order]. This action of the AO was confirmed

Thubagere Mudveerappa Enterprises, Bangalore vs. Income Tax Officer, Ward-6(2)(4), Bangalore

In the result, appeal of the assessee is partly allowed for statistical purposes

ITA 1146/BANG/2023[2017-18]Status: DisposedITAT Bangalore24 Jan 2024AY 2017-18

Bench: Shri Chandra Poojari & Smt. Beena Pillaiassessment Year: 2017-18 Thubagere Mudveerappa Enterprises No.9, 5Th Main Road, Apmc Yard Yeshwanthpur Ito Bangalore 560 022 Vs. Ward-6(2)(4) Karnataka Bangalore Pan No : Aaeft3444R Appellant Respondent Appellant By : Smt. Prathibha R., A.R. Respondent By : Shri Ganesh R. Ghale, Standing Counsel For Department. Date Of Hearing : 24.01.2024 Date Of Pronouncement : 24.01.2024 O R D E R Per Chandra Poojari: This Appeal By Assessee Is Directed Against Order Of Nfac For The Assessment Year 2017-18 Dated 24.11.2023 Passed U/S 250 Of The Income Tax Act, 1961 (In Short “The Act”). The Assessee Has Raised Following Grounds: 1. On The Facts & In The Circumstances Of The Case, The Ld. Cit(A) Erred In Upholding The Order Passed Under Sec. 144 Of The Act By The Learned Assessing Authority Is Opposed To Law & Not Valid & Accordingly Liable To Be Cancelled. 2. The Ld. Cit(A) Ought To Have Given Opportunity To Submit The Details & Allow To Give The Explanation About The Cash Deposits Were Made In Bank. The Deposits Were Made Out Of The Accumulated Cash Balances Relating To His Business. Thus, The Impugned Additions Confirmed By The Ld. Cit(A) Was Uncalled For.

For Appellant: Smt. Prathibha R., A.RFor Respondent: Shri Ganesh R. Ghale, Standing Counsel for Department
Section 115BSection 144Section 250Section 69A

from business receipts/sales receipts, there should not be double addition, one in Thubagere Mudveerappa Enterprises, Bangalore Page 5 of 5 the form of estimation of income on sales and another by way of unexplained income u/s 69A of the Act and due telescoping benefit to be given to the assessee

Veeranna Chandrashekhar Marnal, Hubli vs. Income Tax Officer, Ward-3(1), Hubli

In the result, appeal of the assessee is partly allowed for statistical purposes

ITA 1128/BANG/2023[2017-18]Status: DisposedITAT Bangalore24 Jan 2024AY 2017-18

Bench: SHRI CHANDRA POOJARI (Accountant Member), SMT. BEENA PILLAI (Judicial Member)

For Appellant: Smt. Prathibha R., A.RFor Respondent: Shri Ganesh R. Ghale, Standing Counsel for Department
Section 250Section 69Section 69A

available on record. In this case, the addition was made due to deposit of SBN notes during the time of demonetization and also estimation of income at 10% on sale proceeds. On appeal, ld. CIT(A) has deleted the addition of Rs.11 lakhs out of addition of Rs.19 ... towards cash deposits during demonetization period and also reduced the estimation of income on sale proceeds at 5% and deleted the addition of Rs.6,60,726/- on this count. Now the contention of the assessee’s counsel is that the assessment order as well as CIT(A)’s order

Balupuri Ashupuri Goswami, Mumbai vs. ITO Ward 31.1.3, Now (14.4.1., Mumbai

ITA 2360/MUM/2023[2014-2015]Status: DisposedITAT Mumbai22 Jan 2024AY 2014-2015

Bench: Shri Kuldip Singh & Shri Amarjit Singhassessment Year: 2014-15

For Appellant: Shri Devendra Jain, A.RFor Respondent: Shri Ajay Singh, Sr. D.R

Tribunal in Abhi Developer's case, (2007) 12 SOT 444 pg. 6 M/s. Balupuri Ashupuri Goswami 7.3 The appellant has objected to the estimation of income @20% on the suppressed turnover. In this respect the appellant has stated that the AO should have estimated the income ... original return as well as in the revised return was near to 20% of the gross receipts. The AO while estimating the income on the suppressed gross receipts has also considered the percentage of profit declared by the appellant in the earlier and subsequent years. The AO has placed

Shiva Ranjani Vejja, Hyderabad vs. Income Tax Officer, Ward-12(2), Hyderabad

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

ITA 267/HYD/2020[2013-14]Status: DisposedITAT Hyderabad19 Jan 2024AY 2013-14

Bench: Shri R.K. Panda & Shri Laliet Kumar

For Appellant: Shri Mohd. Afzal, AdvocateFor Respondent: Ms. Sheetal Sarin, Sr. AR
Section 144Section 147Section 148Section 2Section 69A

thereafter, the sum was deposited in the bank account. However, the ld.CIT(A) has not considered the request of the assessee for estimating the income u/s 44AD of the Act on the pretext that assessee has not given any evidence of doing the consultancy business. The ld. AR further submitted ... precluded from raising any objection with regard to jurisdiction after one month of filing the return u/s 148. iii. As regards the estimation of income, the assessee never furnished any information before the AO and hence the AO was justified in treating the entire cash deposit as unexplained money

DCIT, Circle-2(1), Hyderabad vs. Kmc Constructions Limited, Hyderabad

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

ITA 32/HYD/2017[2011-12]Status: DisposedITAT Hyderabad11 Jan 2024AY 2011-12

Bench: Shri Rama Kanta Panda & Shri K. Narasimha Chary

For Appellant: Shri S. Rama Rao, ARFor Respondent: Shri K. Madhusudan, CIT-DR
Section 145(3)

Revenue, the expenditure was proved to be bogus and, therefore, the direction of the learned CIT(A) to the learned Assessing Officer to estimate the income, cannot be sustained. We shall therefore, answer this issue with the following common discussion: Page 2 of 18 M/s. KMC Constructions ... this aspect learned AR submitted that right from 1999-2000, in assessee’s own case, the Revenue has been estimating the income and as is evidenced by the orders of the Tribunal from 1999-2000 consistently the income of the assessee is estimated at 12.5% and 7.5% before depreciation

Kmc Contructions Limited, Hyderabad vs. Addl. CIT, Range-2, Hyderabad

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

ITA 1734/HYD/2016[2011-12]Status: DisposedITAT Hyderabad11 Jan 2024AY 2011-12

Bench: Shri Rama Kanta Panda & Shri K. Narasimha Chary

For Appellant: Shri S. Rama Rao, ARFor Respondent: Shri K. Madhusudan, CIT-DR
Section 145(3)

Revenue, the expenditure was proved to be bogus and, therefore, the direction of the learned CIT(A) to the learned Assessing Officer to estimate the income, cannot be sustained. We shall therefore, answer this issue with the following common discussion: Page 2 of 18 M/s. KMC Constructions ... this aspect learned AR submitted that right from 1999-2000, in assessee’s own case, the Revenue has been estimating the income and as is evidenced by the orders of the Tribunal from 1999-2000 consistently the income of the assessee is estimated at 12.5% and 7.5% before depreciation

Balaji Jewellers, Jaipur vs. ACIT CC -4, Jaipur

In the result, the appeal of the assessee is allowed

ITA 433/JPR/2023[2018-19]Status: DisposedITAT Jaipur04 Jan 2024AY 2018-19

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

For Appellant: Shri Shrawan Kumar Gupta, AdvocateFor Respondent: Shri Ajay Malik, CIT
Section 115BSection 132Section 133ASection 139(1)Section 142Section 143(2)Section 143(3)Section 145(3)Section 234ASection 68

Punjab 50 ITA 433/JP/2023 BALAJI JEWELLERS VS ACIT, CENTRAL CIRCLE-4, JAIPUR (1944) 12 I.T.R. 393” 16. Once Books is rejected only Estimation of Income can be done:The Ld. AO has grossly erred in making assessment by adding Rs. 90,00,000/- in his total income arbitrarily resultant

Yogis Angels Entertainment and Decor Pvt. Ltd, New Delhi vs. ITO Ward 27(4), New Delhi

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

ITA 6074/DEL/2019[2015-16]Status: DisposedITAT Delhi04 Jan 2024AY 2015-16

Bench: Sh. Saktijit Deydr. B. R. R. Kumar

For Appellant: Sh. Samyak Jain, Adv. &For Respondent: Ms. Sapna Bhaita, CIT-DR
Section 145(1)Section 145(3)Section 244ASection 43BSection 44A

submitted that it is settled position of law that in case of rejection of books of accounts by the Assessing Officer, the estimation of income should be made by taking reference to the past history of the assessee. In the instant case the average net profit ratio of the assessee

Alpha Heavy Engineering Pvt. Ltd., Mumbai vs. Income Tax Officer 15(1)(1) Mumbai, Mumbai

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

ITA 2615/MUM/2023[2012-13]Status: DisposedITAT Mumbai29 Dec 2023AY 2012-13

Bench: Shri Amit Shukla () & Ms. Padmavathy S. () Assessment Year: 2012-13 Alpha Heavy Engineering Pvt. Ltd., Ito-15(1)(1), 42, Zarna Apartments Nahur Room No. 456, 4Th Floor, Village Road, Vs. Aayakar Bhavan, Mulund West-400080 Maharishi Karve Road, Churchgate, Mumbai-400020. Pan No. Aajca 1768 M Appellant Respondent

For Appellant: NoneFor Respondent: Mr. A.S. Sant, Sr. DR
Section 250

Accordingly the Ass 142(1) of the Act. Accordingly the Assessing Officer made an essing Officer made an estimation of income @ 20% of total contract charges of estimation of income @ 20% of total contract charges of estimation of income @ 20% of total contract charges of Rs.58,40,000/- to make

Atman Rajnikant Bhesdadiya L/R. Late Shri Rajnikant Lavjibhai Bhedadiya, Rajkot vs. The DCIT, Central Circle-1, Rajkot

In the result, appeal of the assessee in ITA No

ITA 112/RJT/2023[2017-18]Status: DisposedITAT Rajkot20 Dec 2023AY 2017-18

Bench: Shri Waseem Ahmed (Accountant Member), Shri T.R. Senthil Kumar (Judicial Member)

Section 132Section 271ASection 274Section 68

Page No 3 Shri Atman Rajnikant Bhesdadiya. Vs. DCIT of penalty u/s. 271AAB does not arise and penalty cannot be levied on estimation of income. Therefore requested to drop the penalty proceedings. 3.1. The above reply was considered by the A.O. however not satisfied with the same and levied penalty

Rukmani Jewellers Private Limited, Jaipur vs. DCIT Cir.-4 Jaipur, Jaipur

In the result, the appeal of the assessee is allowed

ITA 539/JPR/2023[2017-18]Status: DisposedITAT Jaipur20 Dec 2023AY 2017-18

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Shri Shrawan Kumar Gupta (Adv.)For Respondent: Shri A. S. Nehra (Addl. CIT) a
Section 115BSection 143(2)Section 143(3)Section 145(3)Section 234ASection 68

also noteworthy to mention that that the AO has not given any show cause notices as required u/s 144/145 of the Act before estimation of income by applying the N.P. Rate. It is also ridiculous to note that AO had rejected the books of account ... account audited by Chartered Accountant and the profit may be derived from the audited books of account therefore there is no justification in estimation of income by applying NP rate and accordingly the lower authorities are directed to delete the addition of Rs. 47,72,297/- sustained

Innovators Facade Systems Limited, Mira Road vs. ACIT, Circle -2, Thane

In the result, the appeal by the assessee is allowed

ITA 2792/MUM/2023[2010-11]Status: DisposedITAT Mumbai15 Dec 2023AY 2010-11

Bench: Shri Om Prakash Kant & Shri Sandeep Singh Karhail

For Appellant: Shri Purram TejwaniFor Respondent: Shri H.M. Bhatt
Section 133ASection 142(1)Section 143(2)Section 143(3)Section 250Section 271(1)(c)Section 274Section 37(1)

penalty-imposed u/s.271(1)(c) without appreciating the fact that no penalty should be levied where addition is made on the basis of estimation of income. 5. Appellant craves leave to add, alter, modify or delete any of the grounds of appeal.” 3. The brief facts of the case

Bollam Sampath Kumar Jewellers Private Limited, Warangal vs. ACIT, Circle-3(1), Hyderabad

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

ITA 254/HYD/2023[2017-18]Status: DisposedITAT Hyderabad11 Dec 2023AY 2017-18

Bench: Shri R.K. Panda, Vice- & Shri Laliet Kumarassessment Year: 2017-18 Bollam Sampath Kumar Vs. Asstt. C. I. T. Jewellers (P) Ltd Circle 3(2) Warangal Hyderabad Pan:Aafcb4496H (Appellant) (Respondent) Assessee By: Shri S.Rama Rao, Advocate Revenue By: Smt.Th Vijaya Lakshmi Cit(Dr) Date Of Hearing: 28/11/2023 Date Of Pronouncement: 11/12/2023 Order Per R.K. Panda, Vice-This Appeal Filed By The Assessee Is Directed Against The Order Dated 27.04.2023 Of The Learned Cit (A)-Nfac Delhi, Relating To A.Y.2017-18. 2. Facts Of The Case, In Brief, Are That The Assessee Is A Private Limited Company Engaged In The Business Of Jewellery. It Filed Its Return Of Income On 8.11.2017 Declaring Total Income Of Rs.35,93,490/-. The Case Was Selected For Scrutiny For Verifying The Following: “High Revenue From Operations (Including Other Income) & No Scrutiny In Preceding 5 A.Ys.

For Appellant: Shri S.Rama Rao, AdvocateFor Respondent: Smt.TH Vijaya Lakshmi CIT(DR)
Section 68Section 69A

book results and the rate of profit is almost the same for both the periods, the Assessing Officer could not have resorted to estimation of income and thereby making the addition of Rs.10,97,68,945/- and the learned CIT (A) NFAC was also not justified in sustaining the addition

M/S Kbl Layout, Bangalore vs. ACIT, Central Circle-1(4), Bangalore

In the result, appeal of the assessee is dismissed

ITA 709/BANG/2013[2006-07]Status: DisposedITAT Bangalore07 Dec 2023AY 2006-07

Bench: Shri Chandra Poojari & Smt. Madhumita Royassessment Year: 2006-07

For Appellant: Shri C. Ramesh, A.RFor Respondent: Dr. Nischal, D.R
Section 132Section 153C

will be adjudicated along with ground No.5 M/s. KBL Layout Bangalore Page 11 of 17 6. Ground Nos.3 & 4 are with regard to estimation of income which cannot be applied in the present case as the presumptive taxation at 5% is applicable only when the turnover of the assessee

Joint Commissioner of Income Tax, Ajmer vs. M/S R.P.Wood Products Pvt. Ltd., Ajmer

In the result, appeal of the assessee is allowed

ITA 370/JPR/2023[2018-19]Status: DisposedITAT Jaipur30 Nov 2023AY 2018-19

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

For Appellant: Shri C.M. Agarwal, CAFor Respondent: Mrs. Monisha Choudhary, Addl. CIT fu/kZkfjrh dh vksjls@
Section 132Section 132(4)Section 153ASection 271A

happy with the disclosure given by the assessee and did not verify the factual position with the books of accounts and estimation of income and bring the evidence to unearth or quantify the said income as undisclosed income. Neither the A.O. nor the investigation wing linked the sales recorded

Anil Kumar Paik, Kolkata vs. ACIT, Kolkata

In the result, appeal of the assessee is allowed partly for statistical purposes

ITA 468/KOL/2023[2016-17]Status: DisposedITAT Kolkata29 Nov 2023AY 2016-17

Bench: Shri Sanjay Garg, Hon’Ble & Dr. Manish Borad, Hon’Blei.T.A. No. 468/Kol/2023 Assessment Year: 2016-17 Anil Kumar Paik Acit, Circle-8(1), Kolkata C/O S.N. Ghosh & Associates, Advocates Vs 2, Garstin Place, 2Nd Floor Suite No. 203 Off Hare Street Kolkata - 700001 [Pan : Aflpp6567R] अपीलाथ"/ (Appellant) "" यथ"/ (Respondent) Assessee By : Shri Somnath Ghosh, Advocate Revenue By : Shri P.P. Barman, Addl. Cit, Sr. D/R सुनवाई क" तारीख/Date Of Hearing : 21/09/2023 घोषणा क" तारीख /Date Of Pronouncement: 29/11/2023 आदेश/O R D E R Per Dr. Manish Borad: The Present Appeal Is Directed At The Instance Of The Assessee Against The Order Of The National Faceless Appeal Centre, Delhi (Hereinafter The “Ld. Cit(A)”) Dt. 15/03/2023, Passed U/S 250 Of The Income Tax Act, 1961 (“The Act”) For The Assessment Year 2016-17. 2. The Assessee Has Raised The Following Grounds Of Appeal:-

For Appellant: Shri Somnath Ghosh, AdvocateFor Respondent: Shri P.P. Barman, Addl. CIT, Sr. D/R
Section 143(2)Section 145(3)Section 250Section 43CSection 44A

Circle 8(1), Kolkata for his specious action of assuming jurisdiction u/s. 145(3) of the Income Tax Act, 1961 and thereby estimating an income of Rs. 3,76,28,573/- in a summary manner without adducing on record the genesis thereof and such addition impliedly sustained without any authority ... complete to the satisfaction of the Assessing Authority, he has to assign reasons for such assumption and thereafter, resort to an estimate of income as contemplated in the provisions of s. 144 of the Act. In other words, the statutory prescription contained in the provisions

DCIT, Central Circle-4(3), Mumbai vs. Mangal Royal Jewels Pvt. Ltd., Mumbai

In the result, the appeal filed by the revenue is dismissed and the appeal filed by the asseees is allowed

ITA 3274/MUM/2022[2017-18]Status: DisposedITAT Mumbai29 Nov 2023AY 2017-18

Bench: Shri Br Baskaranshri Pavan Kumar Gadalem/S Mangal Royal Vs. Acit-Cc-1(3), Jewels Pvt Ltd. 29C, Room No.905, 9Thfoor, Shyam Kamal Co- Old Cgo Bldg,Annexe, Operative Housing M.K. Road, Society Ltd, Agarwal Mumbai-400020. Market, M.G. Road, Vile Parle (E), Mumbai-400057. Pan/Gir No. : Aaicm0846R Appellant .. Respondent Dy.Cit-Cc 4(3), Vs. M/S Mangal Royal Central Range-4, Jewels Pvt Ltd. 29C, Room No.1921, Shyam Kamal Co- 19Th Floor, Air India Operative Housing Bldg, Nariman Point, Society Ltd, Agarwal Mumbai-400021. Market, M.G. Road, Vile Parle (E), Mumbai-400057 Pan/Gir No. : Aaicm0846R Appellant .. Respondent Appellant/Respondent Mr.Poojan Mehta.Ar By : Respondent/Appellant By Mr.Prakash Kishinchandani.Dr Date Of Hearing 08.09.2023 Date Of Pronouncement 28.11.2023

Section 131Section 132Section 143(1)

IN THE INCOME TAX APPELLATE TRIBUNAL “D” BENCH, MUMBAI BEFORE SHRI BR BASKARAN, ACCOUNTANT MEMBER SHRI PAVAN KUMAR GADALE, JUDICIAL