Chandalal Verma Vs DCIT/ACIT (ITAT Jaipur)
The Income Tax Appellate Tribunal (ITAT), Jaipur Bench, has dismissed two appeals filed by assessee Chandalal Verma, upholding the additions to his income for assessment years 2011-12 and 2017-18. The Tribunal confirmed the orders of the Commissioner of Income Tax (Appeals), Udaipur, finding no fault in the lower authorities’ reasoning regarding undisclosed income. The core of the dispute revolved around seized documents during a search operation conducted on the assessee’s “Resonance Group.”
Assessment Year 2011-12:
For the assessment year 2011-12, Chandalal Verma had initially filed a return declaring an income of Rs. 11,14,000/-. Following a search action on August 7, 2017, the department reportedly found that an income of Rs. 11,00,000/- had escaped assessment for the financial year 2010-11. Consequently, a notice under Section 148 of the Income Tax Act was issued on March 26, 2018. In response, the assessee filed a revised return on April 25, 2018, declaring an income of Rs. 16,65,000/-, thereby offering an additional Rs. 5,51,000/-. However, the Assessing Officer (AO) ultimately assessed the total income at Rs. 22,14,000/-, making a further addition of Rs. 5,49,000/-.
The assessee challenged this before the CIT(A), who confirmed the AO’s order. Before the ITAT, Verma’s primary arguments for AY 2011-12 included challenges to the validity of the Section 147/148 proceedings, claiming they were bad in law, without jurisdiction, and beyond the permitted time. He also contested the confirmation of the Rs. 5,49,000/- addition, arguing for the full benefit of the Rs. 5,51,000/- offered in the revised return. Additionally, an addition of Rs. 10,00,000/- under Section 69C of the Act, based on “deaf and dumb documents,” was disputed. The assessee also denied liability for interest charged under Sections 234A, 234B, and 234C. An additional ground regarding the absence of a Document Identification Number (DIN) for the order was also raised.
