IN THE INCOME TAX APPELLATE TRIBUNAL PUNE “B” BENCH : PUNE BEFORE DR. MANISH BORAD, ACCOUNTANT MEMBER &

SHRI VINAY BHAMORE, JUDICIAL MEMBER I.T.A.No.987/PUN/2025 (Assessment Year : 2014-15)

(Assessment Year : 2014-15)

(Assessment Year : 2014-15)

(Assessment Year : 2014-15)

(Assessment Year : 2014-15)

(Assessment Year : 2014-15)

(Assessment Year : 2014-15)

(Assessment Year : 2014-15)

For Assessee : Shri Subodh Ratnaparkhi, CA For Revenue : Shri Amit Bobde, CIT Date of Hearing : 20.11.2025 Date of Pronouncement : 27.01.2026

ORDER

PER DR.MANISH BORAD, AM This appeal at the instance of the Revenue for the Assessment Year 2014-15 is directed against the order of National Faceless Appeal Centre (NFAC)/ Commissioner of Income Tax (Appeals), Delhi [“CIT(A)”] dated 13.02.2025 passed under section 250 of the Income Tax Act, 1961 (“Act”) which is arising out of Assessment Order dated 29.12.2017 passed u/s. 147 r.w.s. 143(3) of the Act.

2. In the instant appeal, Revenue has raised following grounds of appeal:-

“1. Whether on the facts and circumstances of the case, the Ld.

CTT(A) is justified in deleting the addition of Rs.7,93,62,371/-

and Rs.86,63,700/- made by the AO on account of on money

receipt in cash.

2. Whether on the facts and circumstances of the case, the Ld.

CIT(A) is justified in not considering the fact that there are clear notings on the seized documents where details of cash payment of Rs. 86,63,700/- are mentioned against Plot No. 367. Makhmalabad that is sold by the assessee to Kokani family.

3. Whether on the facts and circumstances of the case, the Ld.

CIT(A) is justified in not considering the fact that Mr. Fakhruddin Kokani has admitted and accepted that the entries on seized documents were written in his own handwriting and that he has confirmed on oath that he alongwith his sister have purchased said land at 367.

Makhmalabad from assessee.

4. Whether on the facts and circumstances of the case, the Ld.

CIT(A) is justified in not considering the fact that since the notings of cash amount of Rs. 86,63,700/- in cash correspond with notings of Rs.81,33,000/- in cheque amount, the same ratio of cash amount to amount received through banking channel must have been followed for sale of other plots by assessee to members of Kokani family.

5. Whether on the facts and circumstances of the case, the Ld.

CIT(A) is justified in not considering the fact that by not disclosing details of cash transactions, assessee had failed to disclose fully and truly all material facts necessary for assessment and therefore the case of assessee came under the ambit of provisions of Section 147 of the Income Tax Act, 1961.”

3. Brief facts of the case as culled out from the records are that the assessee is a Partnership firm engaged in the business of Land Development at Nashik. Nil income declared in the return of income for A.Y. 2014-15 furnished on 17.11.2014. Return was taken up for scrutiny and assessment u/s.143(3) of the Act completed on 16.12.2016 accepting the returned income. Prior to completion of the assessment, search and seizure action was conducted u/s.132 of the Act by the Investigation Wing of the Income Tax Department of the Kokani Group of Nashik on 08.09.2015. During the course of search, various incriminating documents were found and there was a reference of a sale of Land (owned by assessee) at page 16 and 17 of the seized document at Item No.7 of Annexure A. Further, there was survey action carried out in the case of M/s. PH Infrastructure, Nashik in which one of the partner is Mr. Shashikant Shivchand Parakh who is also partner in the assessee firm M/s.Shree Sai Properties. Based on the information available in the seized material found during the course of search at Kokani Group, notice u/s.148 of the Act was issued on 24.03.2017 after duly recording the reasons and reassessment proceedings were carried out. The assessee in response to notice u/s.148 of the Act submitted vide letter dated 03.04.2017 that return of income for A.Y. 2014-15 filed