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INCOME TAX APPELLATE TRIBUNAL (MUMBAI BENCH)
Saktijit Dey, Vice-President, Makarand Vasant Mahadeokar, Accountant Member
DCIT CC 8(2) – Appellant
Versus
Dr. Charat Singh – Respondent
| Table of Content |
|---|
| 1. assessee's franchise business; search initiated via seized documents. (Para 2 , 3) |
| 2. ao adds unexplained cash based on seized sheets and presumptions. (Para 4 , 5) |
| 3. cit(a) deletes addition for lack of nexus and evidence. (Para 6 , 7 , 8) |
| 4. revenue argues presumptions and seized material prove unaccounted cash. (Para 9 , 11 , 12) |
| 5. cross-objection on 153c jurisdiction held infructuous. (Para 10 , 29 , 30 , 31) |
| 6. assessee defends franchise model; no cash receipt evidence. (Para 13 , 14 , 15 , 16 , 17) |
| 7. tribunal rejects presumption without direct nexus or corroboration. (Para 18 , 19 , 20 , 21 , 22 , 23 , 24 , 25) |
| 8. rebuttable presumptions require independent evidence against third parties. (Para 26 , 27 , 28) |
| 9. revenue appeal dismissed; upholds cit(a) deletion. (Para 32) |
आदेश/ORDER
PER MAKARAND VASANT MAHADEOKAR, AM:
This appeal is filed by the Revenue against the order dated 11.04.2025 passed by the Commissioner of Income Tax (Appeals) – 50, Mumbai [hereinafter referred to as "CIT(A)"] under section 250 of the [hereinafter referred to as "the Act"], arising out of the assessment order dated 08.03.2022 passed by the Assistant Commissioner of Income Tax Central Circl
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