Deputy Commissioner of Income Tax, Central Circle vs M/s Krrish Realtech Private Limited

Parties Involved

Facts Summary

The assessee company, M/s Krrish Realtech Private Limited, filed its return of income for the Assessment Year 2017-18 declaring a loss. During a search action at the premises of the Krrish group of companies, certain documents and digital evidence were seized. WhatsApp messages between Shri Amit Katyal and Shri R.P. Gupta indicated cash receipts amounting to Rs. 24.75 Crores. The Assessing Officer (AO) made an addition of this amount to the income of the assessee under section 69A of the Income Tax Act, 1961. The Commissioner of Income Tax (Appeals) (CIT(A)) deleted this addition, finding insufficient evidence to link the amount to the assessee. The Revenue appealed this decision.…

Legal Issues

• 1. Whether the CIT(A) erred in deleting the addition of Rs. 24,75,00,000/- on account of undisclosed income under section 69A of the Income Tax Act, 1961.
• 2. Whether the order of the CIT(A) is perverse, erroneous, and not tenable on facts and in law.

Judgment Outcome

Decided in favour of Assessee.

Precedents Relied Upon

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