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Jarnalbeer Singh Bhatia vs. DCIT/ACIT, (Central)-3, Indore

Case No: IT(SS)A Nos.19 to 23/Ind/2023 & ITA No. 226/Ind/2023
Court: Income Tax Appellate Tribunal, Indore Bench, Indore
Date: 9/18/2024

Parties Involved

appellantJarnalbeer Singh Bhatia
respondentDCIT/ACIT, (Central)-3, Indore

Facts Summary

Jarnalbeer Singh Bhatia, engaged in goods handling and transportation services through 'M/s Bhatia Transport Services', was subjected to a search under section 132 of the Income-tax Act, 1961. The search led to assessments for assessment years 2013-14 to 2018-19. The assessee and the revenue both appealed against the order of the Commissioner of Income-tax (Appeals)-3, Bhopal. The assessee contested the notional additions made by the Assessing Officer (AO) and the Commissioner of Income-tax (Appeals)-3 (CIT(A)), while the revenue contested the CIT(A)'s decisions on various grounds, including the acceptance of additional evidence and the deletion of certain additions.

Decision in favour of

Partly Assessee / Partly Revenue

Legal Issues

  • 1. Unexplained investment in the form of cash loans and notional interest thereon u/s 69
  • 2. Unexplained investment in jewellery u/s 69
  • 3. Unexplained money in lockers u/s 69A
  • 4. Admission of additional evidences by CIT(A)
  • 5. Unexplained cash credit u/s 68 from M/s Vedic Commotrade Pvt. Ltd.
  • 6. Disallowance of freight expenses u/s 40(a)(ia)

4 further legal issues analysed in the full judgement.

Judgment Outcome

Decided in favour of Partly Assessee / Partly Revenue.

Precedents Relied Upon

1 precedent cited in this judgement.

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