ACIT, Central Circle-1, Raipur Vs. M/s. Wallfort Properties Pvt. Ltd.

Parties Involved

Facts Summary

The assessee, M/s. Wallfort Properties Pvt. Ltd., is a private limited company engaged in real estate development. A search and seizure operation was conducted at the assessee's premises, leading to the discovery of unaccounted cash receipts. The Assessing Officer added the entire amount of Rs.31,58,250/- as unaccounted income. The Commissioner (Appeals) restricted the addition to 25% of the total on-money receipts, amounting to Rs.7,89,563/-. The Revenue appealed against this decision. The assessee also disputed the disallowance of Rs.2,47,05,960/- as bogus expenditure. The assessee provided credible evidence to support the genuineness of the transactions. The Tribunal found that the Assessing Officer's decision to disallow the expenditure was unsustainable.…

Legal Issues

• 1. Whether the Commissioner (Appeals) was justified in restricting the addition of unaccounted income to 25% of the total on-money receipts.
• 2. Whether the disallowance of Rs.2,47,05,960/- as bogus expenditure was justified.

Judgment Outcome

Decided in favour of Partly Assessee / Partly Revenue.

Precedents Relied Upon

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