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31. IT(SS) A No. 46/Ahd./2023 and 434/Ahd./2023; IT(SS) A. No. 119 & 120/Ahd./2023
Robin Ramavtar Goenka vs. ACIT
A.Y.s: 2018-19 & 2019-20 Date of Order : 30.05.2025
Sections: 28, 68, 69C
Only profit element embedded in unaccounted receipts can be taxed and not the entire amount of such receipts.
FACTS
The assessee, engaged in real estate business, was part of Sankalp Group. During the course of search action conducted on 30.10.2018 at the premises of Sankalp group, incriminating material such as handwritten diaries, loose papers, unrecorded bills and other documents were seized. These materials revealed evidence of on-money transactions, unaccounted cash sales and cash payments related to land purchases, brokerage, salaries, personal expenses and purchase of jewellery.
The Assessing Officer (AO) made substantial additions in the hands of the assessee and protective addition in the hands of his accountant.
The AO treated unaccounted receipts as undisclosed income and unaccounted payments as unexplained expenditure under section 69C of the Act. He
