DCIT Vs Ivar Estates Private Limited (ITAT Chennai)
Summary: The Revenue appealed against the order dated 29.01.2026 of the CIT(A)-19, Chennai, which deleted two additions made in the assessment of Ivar Estates Private Limited for AY 2023-24. The assessment under section 143(3) was completed on 27.03.2025 by the DCIT, Central Circle-2(1), Chennai, determining total income at ₹75,73,72,793 against returned income of ₹55,10,63,550. The additions comprised ₹1,76,09,243 towards alleged unaccounted cash receipts from sale of flats and ₹18,87,00,000 towards alleged unexplained cash consideration for acquisition of Vadapalani land.
For the first addition, the Revenue relied upon WhatsApp conversations, loose sheets, ERP data and statements recorded during the search under section 132(4). The Assessing Officer adopted an estimated “median rate” after allowing a standard 5% discount and treated the differential between the assumed rate and recorded consideration as unaccounted cash receipts. The assessee denied receiving any cash and explained that variations in flat prices resulted from negotiated discounts, location, orientation, construction stage, market conditions, bulk bookings and other commercial considerations. It also pointed out that no purchaser had admitted payment of on-money, no cash or corresponding undisclosed asset had been found, and the regular books, registered sale documents, ERP records and banking records had not been rejected.
