Deputy Commissioner of Income Tax, Central Circle -31, New Delhi. Vs. M/s SRC Realtech Pvt. Ltd., M/s Pyramid Buildtech Pvt. Ltd., M/s SRC Buildtech Pvt. Ltd.

Parties Involved

Facts Summary

The case involves three companies: M/s SRC Buildtech Pvt. Ltd, SRC Realtech Pvt. Ltd, and Pyramid Buildtech Pvt. Ltd, all belonging to the SRC group. A search and seizure action under Section 132 was conducted on 14.09.2017 at various business premises of the SRC group. During the search, incriminating documents were found and seized. The Assessing Officer (AO) noted an amount of Rs. 8,23,20,000/- towards some expenses in the seized documents. The AO distributed Rs. 2,74,40,000/- each as unaccounted income of the three companies. The AO concluded that the transactions pertained to unexplained expenses incurred from undisclosed sources. Aggrieved by this addition, the assessees contested the matter before the Commissioner of Income Tax (Appeals) (CIT(A)), who deleted the addition. The Revenue filed appeals against this decision.…

Legal Issues

• 1. Addition of Rs. 2,74,40,000/- made by the AO for A.Y. 2012-13 in respect of M/s SRC Buildtech Pvt. Ltd, SRC Realtech Pvt. Ltd and Pyramid Buildtech Pvt. Ltd.
• 2. Addition of Rs. 25 lakhs made by the AO in the case of M/s SRC Buildtech Pvt. Ltd for A.Y. 2012-13 regarding an unsecured loan.

Judgment Outcome

Decided in favour of Assessee.

Precedents Relied Upon

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