Anand Jhalani Vs Central (ITAT Jaipur)
The Income Tax Appellate Tribunal (ITAT), Jaipur, decided four appeals filed by the assessee for Assessment Years 2013-14 to 2016-17 arising from orders of the Commissioner of Income Tax (Appeals). The principal issues related to the validity of proceedings initiated under Section 153C of the Income Tax Act, limitation, additions under Section 69A for alleged unaccounted loans, estimated interest income, and application of Section 115BBE. As the facts were common, the Tribunal disposed of all appeals through a common order.
The dispute originated from a search conducted on the Ramesh Manihar Group on 7 January 2016, during which electronic data, including excel sheets, was seized. Based on these records, the Investigation Wing concluded that the group acted as finance brokers facilitating cash loans. The Assessing Officer identified the code “A. JHALANI” in the seized material and initiated proceedings under Section 153C against the assessee, alleging that he had advanced unaccounted cash loans through the group. The assessee challenged the jurisdiction, contending that the proceedings were based on information received from the Investigation Wing through the Insight Portal, that a single consolidated satisfaction note had been recorded for four assessment years, and that the proceedings were barred by limitation.
