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13. Pr. CIT – 3 V/s Rhythem Real Estates Pvt Ltd.,
ITA No. 61 OF 2020, dated 19/08/2026, (Bom)(HC)
[Arising from order dated 25th April 2018 in Income Tax Appeal No. 3036/Mum/2016. Assessment Year 2006-07]
Section 69B – Unexplained Investment – On money - Seized documents from third party - contents of the documents seized during the search are presumed to be true - presumption referred section 132(4A), would apply to persons searched and not a third party.
The Assessee-Company was engaged in the business of real estate development. For Assessment Year 2006-07, the Assessee filed its Return of Income on 29th November 2006 declaring a loss of ₹44,492/. The assessment was completed under section 143(3) of the Act vide order dated 5th December 2008 computing the income of the Assessee as ‘Nil’, after disallowing the loss claimed.
Thereafter, on the basis of the information received from the Director of Revenue Intelligence (“DRI”), Mumbai, regarding payment of on-money in cash by the Respondent – Assessee for purchasing properties at New Delhi, the Assessing Officer reopened the assessment for Assessment Year 2006-07 under section 147, by issuing a notice under section 148 on 28th March 2013.
