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Sejal Darshanbhai Lakhani,Rajkot vs Dcit, Cc-1, Rajkot, Rajkot on 19 March, 2026 cites

Amarjeet Beeton Huf, Dhuri vs Acit, C-4, Ludhiana on 4 June, 2018

 Hon'ble ITAT Mumbai in case of Amarjit Singh Bakshi (HUF) v. ACIT [2003] 86 ITD 13 (Delhi) (TM) held that any noting in the loose sheet is no evidence by itself. An entry in the books of account maintained in the regular course of business is relevant for purposes of considering the nature and impact of a transaction, but notings on slips of paper or loose sheets of paper cannot fall in this category. Notings on loose sheets of paper are required to be supported/corroborated by other evidence which may include the statement of a person, who admittedly is a party to the notings.
Income Tax Appellate Tribunal - Chandigarh Cites 2 - Cited by 16 - Full Document

Assistant Commissioner Of Income Tax, ... vs Williamson Financial Services ... on 6 July, 2022

(i) Rejection Of Books of accounts & Estimation Of Profit by the assessing officer After thorough examination of the response to show cause notice and dismissing various contentions raised by the assessee in its reply, it has been made clear that the seized/ impounded data is accurate, reliable and self-explanatory. Further, there is also no doubt that the accounts of the assessee where all the transactions are not reflected cannot be relied upon as they present incomplete and incorrect state of affairs of business of the assessee and requires to be disregarded invoking the provisions of section 145(3) of the Act. Accordingly, provisions of section 145(3) are invoked herewith and the assessment of total income of the assessee Page 18 of 38 iTA No.751 To 755/RJT/2024 & ITA No.740 To 742/RJT/2024 Sejal Darshanbhai Lakhani is being made after taking into account all relevant material gathered during the search and the assessment proceedings. As per the material gathered during the search and submissions available on records the assessee is found to have indulged in the practice of suppressing both receipts (on account of sale) and payments (on account of purchase) made for the projects undertaken / developed during the year. There is no uniform method that can be employed to compute income when part receipts on account of sale are not included on the books. The method differs from case to case depending upon various factors le. type of business, modus. operandi of the assessee, sufficiency of data available for estimation etc. In a case where the evidence available on record contains details of corresponding unaccounted payments which are also partly included on the books, such partly recorded payments should also be taken into consideration. Taxing the receipts only has never been the motto of the Income-tax Act.In this regard, the observation of the Supreme Court in CIT v. Williamson Financial Services [2007] 165 Taxman 638 (SC) is reproduced below:
Income Tax Appellate Tribunal - Gauhati Cites 77 - Cited by 1 - Full Document

Panna Lal Kumawat, Jaipur vs Acit, Central Circle-3, Jaipur, Jaipur on 5 May, 2022

Those expenditure must have been made from this on-money. Therefore, after going through the well-reasoned order of the Ld.CIT(A), IT(SS)A No.289 Ahd/2018 (7 Others) Greenfield Reality P. Ld. Vs. DCIT and in the light of judgment of Hon'ble jurisdictional High Court in the case of Panna Corporation (supra) as well as Koshor Mohanlal Telwala (supra), we are of the view that only element of income embedded in the on-money received by the assessee for booking of flats/shops in "Vesu Project" is required to be assessed in its hand in all these years.
Income Tax Appellate Tribunal - Jaipur Cites 24 - Cited by 3 - Full Document

Dharambir Khattar, Gurgaon vs Acit, Central Circle-6, New Delhi on 2 February, 2023

Hon'ble ITAT in the case of Subhash Khattar vs. ACIT in ITA No. 902/Del/2015 (which is affirmed by Hon'ble Delhi High Court in ITA No. 60/2017) has held that-  merely because name of the assessee is appearing in the said hard disk cannot be a basis for arriving at a definite conclusion in absence of corroborative evidence in support that the assessee has also paid amount of Rs. 3,21,00,000 in cash.  Huge addition of Rs. 3,21,00,000 cannot be made in a casual manner.
Income Tax Appellate Tribunal - Delhi Cites 9 - Cited by 3 - Full Document

Dy. Commissioner Of Income Tax, ... vs Alpha Villas Private Limited, ... on 12 June, 2023

In the light of the above judgement of the Hon'ble Supreme Court, in the case of Happy Home Corporation (supra), and Hon'ble jurisdictional High Court of Gujarat in the case of Shivalik Buildwell Pvt Ltd(supra) and decision of Ahmedabad Tribunal, in the case of M/s D R. Construction, we find that unaccounted profit estimated on 'on- money' receipt is required to be taxed in the year in which sale deed is executed by assessee or significant risk and rewards is transferred to buyer. As in case in hand, the assessee has been following revenue recognition method on execution of sale deed, only on-money receipt as computed in present case would be taxable in the year in which sale deed is executed and not when 'on-money' was received. Besides, we find that ICDS-III is not applicable to the assessee under consideration, therefore, we dismiss the ground raised by the revenue."
Income Tax Appellate Tribunal - Hyderabad Cites 8 - Cited by 0 - Full Document
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