Manoj Madanlal Chhajed Vs ACIT (ITAT Pune)
ITAT Pune deletes addition of Rs. 39.69 Crores alleging accommodation entries, unexplained income and unexplained expenditure solely on the basis of statement of the assessee and loose papers/ sheets/ diaries.
FULL TEXT OF THE ORDER OF ITAT PUNE
These are the cross appeals filed by the assessee as well as by the Revenue. The appeals in IT(SS)A Nos.91 to 96/PUN/2022 filed by the assessee are directed against the order of ld. Commissioner of Income Tax (Appeals)-11, Pune dated 29.07.2022 for the assessment years 2012-13 to 2017-18. The cross appeals in in IT(SS)A Nos.97 & 98/PUN/2022 filed by the Revenue are directed against the order of ld. Commissioner of Income Tax (Appeals)-11, Pune dated 29.07.2022 for the assessment years 2012-13 & 2015-16. The appeal of the assessee in ITA No.725/PUN/2022 is directed against the order of ld. Commissioner of Income Tax (Appeals)-11, Pune [‘the CIT(A)’] dated 29.07.2022 for the assessment year 2018-19.
2. Since the identical facts and common issues are involved in all the above captioned nine cross appeals, we proceed to dispose of the same by this common order.
3. Briefly, the facts of the case are that the assessee is an individual engaged in the business of dealing in the real estate/property and carrying on business under the name and style of “M/s. Siddhi Properties” (a proprietary concern). The particulars of Returns of Income filed by the assessee u/s 139(1) of the Income Tax Act, 1961 (‘the Act’) are detailed below :-
