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32 results for “house property”+ House Propertyclear

Sorted by relevance

Mumbai6,500Delhi5,077Bangalore1,947Chennai1,728Kolkata1,016Karnataka867Hyderabad726Jaipur679Ahmedabad630Pune560Chandigarh397Surat317Indore255Telangana240Cochin233Visakhapatnam166Amritsar152Rajkot144Nagpur133Raipur125Lucknow117SC88Patna87Cuttack84Calcutta80Agra78Jodhpur50Guwahati39Dehradun32Varanasi26Rajasthan24Jabalpur23Kerala22Allahabad20Ranchi16Panaji16Orissa9Punjab & Haryana6A.K. SIKRI ROHINTON FALI NARIMAN5Gauhati2Himachal Pradesh2Andhra Pradesh2J&K1T.S. THAKUR ROHINTON FALI NARIMAN1ANIL R. DAVE SHIVA KIRTI SINGH1ANIL R. DAVE L. NAGESWARA RAO1ARIJIT PASAYAT C.K. THAKKER1H.L. DATTU S.A. BOBDE1D.K. JAIN JAGDISH SINGH KHEHAR1

Key Topics

Section 143(3)30Section 26325Section 54B23Addition to Income21House Property17Section 14713Section 153A12Section 54F11Section 13210Disallowance

LATE SHRI CHANDRA PRAKASH CHAUDHARY THROUGH LEAGAL HEIR MRS. ANJU CHAUDHARY,NEW DELHI vs. DCIT, CIRCLE- 1 , DEHRADUN

ITA 4259/DEL/2018[2009-10]Status: DisposedITAT Dehradun18 Dec 2023AY 2009-10
Section 143(3)Section 153A(1)(b)Section 43Section 43(5)

House Property income Rs. 1,37,980/- Business Income Rs. 34,04,580/- Short Term Capital Gain Rs. 26,383/- Income

LATE SHRI CHANDRA PRAKASH CHAUDHARY THROUGH LEAGAL HEIR MRS. ANJU CHAUDHARY,NEW DELHI vs. DCIT, CIRCLE- 1 , DEHRADUN

ITA 4258/DEL/2018[2008-09]Status: DisposedITAT Dehradun18 Dec 2023AY 2008-09
Section 143(3)Section 153A(1)(b)

Showing 1–20 of 32 · Page 1 of 2

9
Deduction9
Section 271(1)(c)8
Section 43
Section 43(5)

House Property income Rs. 1,37,980/- Business Income Rs. 34,04,580/- Short Term Capital Gain Rs. 26,383/- Income

MRS. DHOOMI DEVI,CHAMOLI vs. ITO, W-1(4)4, SRINAGAR, CHAMOLI

In the result, appeal of the assessee is partly allowed

ITA 149/DDN/2024[2022-23]Status: DisposedITAT Dehradun13 Feb 2026AY 2022-23

Bench: Shri Yogesh Kumar U.S & Shri Manish Agarwal[Through Virtual Mode] [Assessment Year : 2022-23] Mrs. Dhoomi Devi Vs Ito C/O-Hotel Udai Palace Near . Ward-1(4)4 Narsingh Temple Srignagar, Chamoli Joshimath Chamoli, Uttarakhand-246174 Uttarakhand-246443 Pan-Adkpd6984B Appellant Respondent Assessee By Shri Tarandeep Singh, Adv. Revenue By Shri A.S. Rana, Sr. Dr Date Of Hearing 08.12.2025 Date Of Pronouncement 13.02.2026 Order Per Manish Agarwal, Am : The Present Appeal Is Filed By The Assessee Against The Order Dated 08.08.2024 By Ld. Commissioner Of Income Tax (A), National Faceless Appeal Centre (“Nfac”), Delhi [“Ld. Cit(A)”] In Appeal No. Nfac/2021-22/10329482 Passed U/S 250 Of The Income Tax Act, 1961 [“The Act”] Arising From The Assessment Order Dated 05.03.2024 Passed U/S 143(3) R.W.S. 144B Of The Act Pertaining To Assessment Year 2022-23. 2. Brief Facts Of The Case Are That Assessee Is An Individual & The Case Was Selected For Scrutiny Under Cass For Reason I.E. “Large Investment In Immovable Property As Compared To The Total Income”. The Ao Than Passed The Assessment Order U/S 143(3) R.W.S. 144B On 05.03.2024 At A Total Income Of Inr 2,70,31,224/- As Against The Total Income Declared At Inr 29,45,000/- In The Return Of Income Filed By The Assessee.

Section 143(3)Section 250Section 54FSection 54F(1)

properties inherited by the appellant are not a "residential house as they are commercial properties or in commercial

OMWATI,DEHRADUN vs. PR.CIT, DEHRADUN

In the result, the appeal of the assessee is allowed

ITA 6853/DEL/2017[2010-11]Status: DisposedITAT Dehradun15 Sept 2023AY 2010-11

Bench: Shri Challa Nagendra Prasad & Shri M. Balaganeshsmt. Omwati Pr. Cit W/O Sh. Dariyav Singh Dehradun 171/1, Vasant Vihar, Vs. Dehradun Pan-Aanpw 6438K (Appellant) (Respondent)

Section 143(3)Section 147Section 148Section 263Section 54B

house property and income from business. The return of income for A.Y.2010-11 was filed on 30/09/2010 declaring total

KAMAL KISHORE JAISWAL,DEHRADUN vs. ACIT, DEHRADUN

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

ITA 991/DEL/2017[2007-08]Status: DisposedITAT Dehradun27 Apr 2022AY 2007-08

Bench: Dr. B. R. R. Kumar & Sh. Yogesh Kumar U.S.Assessment Year: 2007-08 Kamal Kishore Jaiswal, Vs Asst. Commissioner Of Income Tax, 23/25, Pritam Road, Central Circle, Dalanwala, Dehradun. Dehradun. (Appellant) (Respondent) Pan No. Acdpk1166C Assessee By : None Revenue By : Sh. N.S. Jangpangi, Cit-Dr Date Of Hearing: 25.04.2022 Date Of Pronouncement: 27.04.2022 Order Per Yogesh Kumar U.S.: This Appeal Has Been Filed By The Assessee Against The Order Of The Ld. Cit(A)-Iv, Kanpur Dated 16.01.2017. 2. Brief Facts Of The Case Are That, During The Year Under Consideration, The Assesse Had Sold Plot On Which Long Term Capital Gain (Ltcg)Of Rs.22,62,367/- Has Been Declared In His Return Of Income Filed Under Section 139 Of The Act. Out Of Ltcg, Rs.13,95,000/- Has Been Claimed Exempt Under Section 54F Of The Act, Which Was Invested In The Purchase Of Residential House Property Amounting To Rs.38,95,000/- At Pritam Road, Dehradun. A Loan Amount Of Rs.25 Lakh Had Been Availed From Hdfc Bank For Purchase Of The Said Property. The Balance Amount Of Rs.8,67,367/- As Capital Gain Was Offered To Tax. At The Time Of 2 Kamal Kishore Jaiswal Filing Return Under Section 153A Of The Act, The Assessee Claimed Entire Amount Of Long Term Capital Gain Exempt Under Section 54F Act, Therefore, A Show Cause Notice Has Been Issued To The Assesse & A Reply Has Been Submitted By The Assesse On 05.02.2013 In The Following Manner:

For Appellant: NoneFor Respondent: Sh. N.S. Jangpangi, CIT-DR
Section 139Section 147Section 153ASection 217(1)(c)Section 54F

house property amounting to Rs.38,95,000/- at Pritam Road, Dehradun. A loan amount of Rs.25 lakh had been

LAT SMT. SAROJ BANSAL,DEHRADUN vs. ITO, WARD-2(3), DEHRADUN

In the result, the appeal is allowed for statistical purposes

ITA 3941/DEL/2018[2013-14]Status: DisposedITAT Dehradun23 Jun 2023AY 2013-14
Section 147Section 54F

properties would only be income from business and not income from capital gains. Consequently, learned Assessing Officer had also denied the claim of deduction under section 54F of the Act in respect of reinvestment made in new house

OM PRAKASH GUPTA,DEHRADUN vs. DCIT, DEHRADUN

In the result, Appeal of the Assessee is allowed

ITA 130/DDN/2025[2023-24]Status: DisposedITAT Dehradun09 Jan 2026AY 2023-24

Bench: Shri S. Rifaur Rahman & Shri Yogesh Kumar U.S.Om Prakash Gupta Vs Deputy/Assistant C/O. Matta Garg & Co. Commissioner Of Income Tax, 15, Astley Hall, Dehraudn, Income Tax Office, Uttarakhand Investigation Wing, 13 A, Pan: Abipg9323M Subhash Road, Central Circle, Dehradun, Uttarakhand Appellant Respondent Assessee By Sh. S. K. Matta, Ca Revenue By Sh. S. K. Chatterjee, Cit, Dr Date Of Hearing 12/11/2025 Date Of Pronouncement 09/01/2026

Section 132Section 143(3)Section 69

house property, business and income from other sources. A search and seizure operation u/s 132 of the Income

SHALINI SRIVASTAVA,HALDWANI vs. WARD 2(1)(1) HALDWANI/, HALDWANI

In the result, appeal of the assessee is partly allowed

ITA 121/DDN/2025[2019-20]Status: DisposedITAT Dehradun24 Dec 2025AY 2019-20

Bench: Shri Yogesh Kumar U.S & Shri Manish Agarwal[Through Virtual Mode] [Assessment Year :2019-20] Shalini Srivastava Vs Ward-2(1)(1) Sheeshmahal, Opp. Haldwani Filter House, Uttarakhand Kathgodam, Haldwani, Uttarakhand-263139 Pan-Apyps8567D Appellant Respondent Assessee By Shri Prashant Kackar, Ca Revenue By Shri Amar Pal Singh, Sr.Dr Date Of Hearing 09.10.2025 Date Of Pronouncement 24.12.2025 Order Per Manish Agarwal, Am : The Present Appeal Is Filed By The Assessee Against The Order Dated 08.07.2025 By Ld. Commissioner Of Income Tax (A), National Faceless Appeal Centre (“Nfac”), Delhi [“Ld. Cit(A)”] In Appeal No. Nfac/2018-19/10096852 Passed U/S 250 Of The Income Tax Act, 1961 [“The Act”] Arising Out Of The Assessment Order Dated 28.09.2021 Passed U/S 144 R.W.S. 144B Of The Act Pertaining To Assessment Year 2019-20. 2. Brief Facts Of The Case Are That Assessee Filed Her Return Of Income, Declaring Income From House Property Of Inr 51,754/- & Income Under The Head “Other Sources” Of Inr 17,56,736/-. The Total Income Of Inr 18,08,490/- Was Claimed As Set Off Against The Current Year Losses From Business & Profession Of Inr 31,04,998/- & Thus Total Income At Inr Nil Was Declared After Claiming Of Deduction Under Chapter Via Of Inr 1,56,918/-. The Return Of Income Was Selected For Complete Scrutiny. Notices U/S 143(2) Followed By Notices U/S 142(1) Were Issued From Time To Time Which Were Not Complied With. In Absence Of Any Reply By The Assessee, Order Was Passed U/S 144 As Per Information Available & Total Income Of The Assessee Was Assessed At Inr 13,32,38,065/- By Making Various Addition.

Section 142(1)Section 143(2)Section 144Section 250Section 68

house property of INR 51,754/- and income under the head “other sources” of INR 17,56,736/-. The total

INSTITUTE OF CLINICAL RESEARCH INDIA SOCIETY,DEHRADUN vs. CIT(A), DEHRADUN

Appeal is allowed

ITA 45/DDN/2024[2012-13]Status: DisposedITAT Dehradun13 Jun 2025AY 2012-13

Bench: Shri Satbeer Singh Godara & Shri M. Balaganesh(Through Video Conferencing) Assessment Year: 2012-13 Institute Of Clinical Research Vs. Commissioner Of Income India Society, Tax (Appeals), 1St Floor, Building No.1, Dehradun Treenetra Vihar, Near Kargt Chowk, Dehradun Pan :Aabai3710P (Appellant) (Respondent) Assessee By None Department By Sh. Amar Pal Singh, Sr. Dr

Section 11Section 12ASection 194Section 194JSection 2(15)Section 40

house property iii. Profits and gains from business or profession iv. Capital gains v. Income from other sources

ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-1(1)(1), DEHRADUN, SUBHASH ROAD, DEHRADUN vs. AMBEY ASSOCIATES, RAJPUR ROAD, DEHRADUN

Appeal of the Revenue is dismissed being devoid of any merit

ITA 68/DDN/2023[2015-16]Status: DisposedITAT Dehradun21 Feb 2025AY 2015-16

Bench: SHRI VIKAS AWASTHY (Judicial Member), SHRI AVDHESH KUMAR MISHRA (Accountant Member)

For Appellant: Shri Amar Pal Singh, Sr. DR (Through VC)For Respondent: Shri Rajiv Sahni, Chartered Accountant
Section 143(3)

House Property by the assessee. The ld. AR contended that the assessee is not engaged in the business

AMAR NATH AHUJA,DEHRADUN vs. DCIT, CENTRAL CIRCLE, DEHRADUN

Accordingly not sustainable. The ground no. 1 as raised stand allowed

ITA 8349/DEL/2018[2016-17]Status: DisposedITAT Dehradun07 Dec 2023AY 2016-17

Bench: Sh. Shamim Yahya & Sh. Anubhav Sharmaita No. 8349/Del/2018, A.Y. 2016-17 Amar Nath Ahuja Vs. Dcit C/O. Matta Garg & Co., Central Circle, 15-Astley Hall, Dehradun Dehradun Uttarakhand, Pan : Acdpa9783D (Appellant) (Respondent)

For Appellant: Sh. S.K.Matta, CAFor Respondent: Sh. N.S. Jangpangi, CIT-DR
Section 153A(1)(b)

house property, business and profession, capital gains and other sources. A search and seizure operation was conducted in the case

SUSHILA BISHT,DEHRADUN vs. ADD. CIT RANGE-02, DEHRADUN

In the result, the appeal of the Assessee is allowed

ITA 3288/DEL/2019[2014-15]Status: DisposedITAT Dehradun15 Sept 2023AY 2014-15

Bench: Sh. C. N. Prasad & Shri M. Balaganesh(Through Video Conferencing) Sushila Bisht, Vs. Addl Cit, Ajabpur Kalan, C-100, Shanti Range-02, Vihar, Phase-1, Dehradun Dehradun (Appellant) (Respondent) Pan: Ajepb0822E

For Appellant: Shri Rajeev Sahani, CAFor Respondent: Shri Parmod Verma, Sr. DR
Section 143(3)Section 269Section 269SSection 271D

house property for Rs. 75 lakhs. b) The Assessee borrowed unsecured loan from Shri Bikram Singh Bisht (husband

DARIYAV SINGH,DEHRADUN vs. PR. CIT, DEHRADUN

In the result, both the appeals of the assessee are allowed

ITA 2029/DEL/2018[2010-11]Status: DisposedITAT Dehradun28 Jun 2023AY 2010-11

Bench: Shri Saktijit Dey & Shri M. Balaganeshsh. Sanjay Kumar Pr. Cit 170, Vasant Vihar-1 Dehradun Dehradun Vs. Pan-Akkpk 1007F (Appellant) (Respondent) Sh. Dariyav Singh Pr. Cit 28-Chakrata Road, Dehradun Dehradun Vs. Pan-Awkps 6026L (Appellant) (Respondent) Appellant By Dr. Rakesh Gupta & Mr. Sherey Jain, Advocates Respondent By Mr. N.S.Jangpangi, Cit-Dr

Section 143(3)Section 147Section 263Section 54B

house property. The return of income for A.Y.2010-11 was filed on 30/09/2010 declaring total income of Rs.11,80,610/- showing

SANJAY KUMAR,DEHRADUN vs. PRCIT, DEHRADUN

In the result, both the appeals of the assessee are allowed

ITA 2187/DEL/2018[2010-11]Status: DisposedITAT Dehradun23 Jun 2023AY 2010-11

Bench: Shri Saktijit Dey & Shri M. Balaganeshsh. Sanjay Kumar Pr. Cit 170, Vasant Vihar-1 Dehradun Dehradun Vs. Pan-Akkpk 1007F (Appellant) (Respondent) Sh. Dariyav Singh Pr. Cit 28-Chakrata Road, Dehradun Dehradun Vs. Pan-Awkps 6026L (Appellant) (Respondent) Appellant By Dr. Rakesh Gupta & Mr. Sherey Jain, Advocates Respondent By Mr. N.S.Jangpangi, Cit-Dr

Section 143(3)Section 147Section 263Section 54B

house property. The return of income for A.Y.2010-11 was filed on 30/09/2010 declaring total income of Rs.11,80,610/- showing

RAJU VERMA,DEHRADUN vs. DCIT, CENTRAL CIRCLE, DEHRADUN

In the result, appeals are allowed as indicated above

ITA 7797/DEL/2017[2010-11]Status: DisposedITAT Dehradun10 May 2023AY 2010-11

Bench: Shri Saktijit Dey & Shri M. Balaganesh

For Appellant: Shri K.K. Juneja, AdvocateFor Respondent: Shri N.S. Jangpangi, CIT/DR
Section 132Section 153ASection 271(1)(c)

house property and other sources. There was a search and seizure operation conducted u/s. 132 of the Act on the assessee

DEEPAK MITTAL,UTTRAKHAND vs. DCIT, CENTRAL CIRCLE, DEHRADUN

In the result, the appeal of the assessee is dismissed

ITA 3972/DEL/2016[2007-08]Status: DisposedITAT Dehradun18 Oct 2022AY 2007-08

Bench: Shri Kul Bharat & Dr.B.R.R.Kumar[Through Video Conferencing At New Delhi]

Section 132Section 143Section 153ASection 153A(1)(a)Section 69C

house property and other sources. A search under section 132 of the Income Tax Act, 1961 (“the Act”) has been

SH. DEEPAK MITTAL,UTTRAKHAND vs. DCIT, DEHRADUN

In the result, the appeal of the assessee is dismissed

ITA 3973/DEL/2016[2011-12]Status: DisposedITAT Dehradun18 Oct 2022AY 2011-12

Bench: Shri Kul Bharat & Dr.B.R.R.Kumar[Through Video Conferencing At New Delhi]

Section 132Section 143Section 153ASection 153A(1)(a)Section 69C

house property and other sources. A search under section 132 of the Income Tax Act, 1961 (“the Act”) has been

RISHI BANSAL,DEHRADUN vs. DCIT, DEHRADUN

In the result, the appeals of the assessee are allowed

ITA 4845/DEL/2016[2012-13]Status: DisposedITAT Dehradun29 Apr 2022AY 2012-13

Bench: Dr. B. R. R. Kumarsh. Yogesh Kumar Usita No. 4845/Del/2016 : Asstt. Year: 2012-13 Ita No. 4846/Del/2016 : Asstt. Year: 2013-14 Rishi Bansal, Vs Dcit, 132, Doon Palm City, Central Circle, Pathri Bagh, Dehradun Dehradun (Appellant) (Respondent) Pan No. Akvpb7754R Assessee By : Sh. Vivek Aggarwal, Ca Revenue By : Sh. N. S. Jangpangi, Cit Dr Date Of Hearing: 26.04.2022 Date Of Pronouncement: 29.04.2022 Order Per Dr. B. R. R. Kumar: These Appeals Have Been Filed By The Assessee Against The Orders Of The Ld. Cit(A)-2, Dehradun Dated 31.03.2016. 2. In Ita No. 4845/Del/2016, Following Grounds Have Been Raised By The Assessee: “1. That The Impugned Proceeding Initiated U/S 153A & Passing The Impugned Order Under That Section Is Bad In Law & Without Jurisdiction & Addition Are Also Made Without Any Incriminating Material Found During The Course Of Search. 2. That Having Regard To The Fact & Circumstances Of The Case, Ld. Cit(A) Has Erred In Law & On Facts In Confirming The Action Of Ao In Making Addition Of Rs.50 Lacs Which Was Made By The Ao Only On The Basis Of Alleged Statement Which Has Even Being Retracted On 09.07.2012 By The Assessee. Thus The Addition Is Not Sustainable. 3. That In Any Case & In Any View Of The Matter Action Of Ld. Cit(A) In Making Addition Of Rs.50 Lacs Is Bad In Law & Against The Facts & Circumstances Of The Case.“

For Appellant: Sh. Vivek Aggarwal, CAFor Respondent: Sh. N. S. Jangpangi, CIT DR
Section 132Section 132(4)Section 153A

house property and other sources. A search u/s 132 of the Income Tax Act, 1961 took place in the business

RISHI BANSAL,DEHRADUN vs. DCIT, DEHRADUN

In the result, the appeals of the assessee are allowed

ITA 4846/DEL/2016[2013-14]Status: DisposedITAT Dehradun29 Apr 2022AY 2013-14

Bench: Dr. B. R. R. Kumarsh. Yogesh Kumar Usita No. 4845/Del/2016 : Asstt. Year: 2012-13 Ita No. 4846/Del/2016 : Asstt. Year: 2013-14 Rishi Bansal, Vs Dcit, 132, Doon Palm City, Central Circle, Pathri Bagh, Dehradun Dehradun (Appellant) (Respondent) Pan No. Akvpb7754R Assessee By : Sh. Vivek Aggarwal, Ca Revenue By : Sh. N. S. Jangpangi, Cit Dr Date Of Hearing: 26.04.2022 Date Of Pronouncement: 29.04.2022 Order Per Dr. B. R. R. Kumar: These Appeals Have Been Filed By The Assessee Against The Orders Of The Ld. Cit(A)-2, Dehradun Dated 31.03.2016. 2. In Ita No. 4845/Del/2016, Following Grounds Have Been Raised By The Assessee: “1. That The Impugned Proceeding Initiated U/S 153A & Passing The Impugned Order Under That Section Is Bad In Law & Without Jurisdiction & Addition Are Also Made Without Any Incriminating Material Found During The Course Of Search. 2. That Having Regard To The Fact & Circumstances Of The Case, Ld. Cit(A) Has Erred In Law & On Facts In Confirming The Action Of Ao In Making Addition Of Rs.50 Lacs Which Was Made By The Ao Only On The Basis Of Alleged Statement Which Has Even Being Retracted On 09.07.2012 By The Assessee. Thus The Addition Is Not Sustainable. 3. That In Any Case & In Any View Of The Matter Action Of Ld. Cit(A) In Making Addition Of Rs.50 Lacs Is Bad In Law & Against The Facts & Circumstances Of The Case.“

For Appellant: Sh. Vivek Aggarwal, CAFor Respondent: Sh. N. S. Jangpangi, CIT DR
Section 132Section 132(4)Section 153A

house property and other sources. A search u/s 132 of the Income Tax Act, 1961 took place in the business

GULSHAN KUMAR,DEHRADUN vs. ITO, WARD- 1(3), DEHRADUN

In the result, the appeal of the assessee is allowed

ITA 7350/DEL/2017[2012-13]Status: DisposedITAT Dehradun26 Apr 2022AY 2012-13

Bench: Dr. B. R. R. Kumarsh. Yogesh Kumar Usita No. 7350/Del/2017 : Asstt. Year: 2012-13 Gulshan Kumar, Vs Income Tax Officer, 40, Anand Chowk, Ward-1(3), Dehradun Dehradun (Appellant) (Respondent) Pan No. Acdpk1177F Assessee By : Sh. Romal Jain, Ca Revenue By : Sh. N. C. Upadhyay, Sr. Dr Date Of Hearing: 25.04.2022 Date Of Pronouncement: 26.04.2022 Order Per Dr. B. R. R. Kumar: This Appeal Has Been Filed By The Assessee Against The Order Of The Ld. Cit(A), Haldwani Dated 10.08.2017. 2. Following Grounds Have Been Raised By The Assessee: “1. That On The Facts & In Law The Orders Passed By Assessing Officer (Hereinafter Referred To As The "Ao7 & Commissioner Of Income Tax (Appeals) {Hereinafter Referred To As The "Cit(A)) Are Void-Ab-Initio & Bad In Law. 2. That On Facts & In Law The Cit(A) Has Erred In Upholding The Addition Made By Learned Ao Of Rs 8,74,000/- On Account Of Sale Of Jewellery Made By The Assessee Despite Of The Fact That The Said Sale Was Truly Declared By Assessee In Its Return Of Income. The Addition Made By Learned Ao & Sustained By Hon’Ble Cit (A) Has Been Done On Erroneous & Frivolous Grounds Such As Item Wise Detail Of Sale Of Jewellery Not Provided, Buyer Not Being In Business Of Jewellery & Other Petty Issues. Both

For Appellant: Sh. Romal Jain, CAFor Respondent: Sh. N. C. Upadhyay, Sr. DR
Section 133(6)Section 2Section 80D

house property income, 3 Gulshan Kumar business income from own business of civil construction work and share of profit