Ganesh Prasad Khetan Vs PCIT (ITAT Raipur)
Summary: The appeal was filed by M/s. Ganesh Prasad Khetan against the order dated 19.03.2026 passed by the Pr. Commissioner of Income Tax, Raipur-1 under Section 263 of the Income-tax Act, 1961 for Assessment Year 2022-23. The appeal was heard by the Income Tax Appellate Tribunal, Raipur Bench, “DB”, comprising Shri R.K. Panda, Vice President and Shri Partha Sarathi Chaudhury, Judicial Member. The hearing took place on 04.08.2026 and the order was pronounced on 06.08.2026.
The assessee had filed its return of income for A.Y. 2022-23 on 17.10.2022 declaring total income of Rs.6,10,41,300/-. The case was selected for scrutiny through CASS for substantial increase in capital in a year and high interest expenditure and huge advance in excess of total proprietors/partners fund. The assessment was thereafter completed under Section 143(3) read with Section 144B on 21.03.2024 accepting the returned income.
The Pr. CIT subsequently invoked revisionary jurisdiction under Section 263 of the Income-tax Act, 1961 on two issues: suppression of business receipts and unsecured loans.
On the business-receipt issue, the Pr. CIT observed that, according to the 26AS details, the assessee had business receipts of Rs.1,03,42,28,914/- from two major deductors, whereas the books reflected business receipts of Rs.1,00,18,40,156/-. The difference was stated to be Rs.3,23,88,758/-. The Pr. CIT further observed that TDS of Rs.2,06,84,591/- had been claimed and, relying upon Section 199(1), concluded that the higher amount reflected through the relevant TDS information ought to have been accounted for. The Pr. CIT accordingly treated the difference as suppression of business receipts.
