Facts of the Case

The assessee, SKZ Developers LLP, engaged in real-estate development, filed its returns of income for Assessment Years 2021-22 and 2022-23. A search and seizure action under Section 132 was conducted on 28.09.2021 in the B-Safal and City Estate Group, during which certain loose papers, excel files and digital data were found indicating alleged unaccounted cash transactions relating to sale of units in the projects “Privilon” and “Paarijat Eclate”.

Based on the seized material, the Assessing Officer concluded that the assessee had sold units at rates higher than those recorded in registered sale deeds and had received “on-money” in cash. The AO estimated the project cost based on seized excel files, applied assumed sale rates, and made additions of ₹20.24 crore for Privilon and ₹33.12 crore for Paarijat Eclate by treating the entire difference as unaccounted income. The AO also made additions towards deemed rent under Section 23(5) in respect of unsold units.

On appeal, the CIT(A) rejected the AO’s methodology of taxing the entire alleged on-money, estimated a flat fair market sale rate of ₹6,500 per sq. ft., restricted taxation to profit element @17%, and reduced deemed rent to 3% of fair market value. Both the assessee and the Revenue filed cross-appeals before the Tribunal.

Issues Involved

Whether alleged on-money receipts on sale of real-estate units could be sustained solely on the basis of loose sheets, excel files and WhatsApp chats without corroborative evidence, whether estimation of uniform sale rate and profit element was justified, and whether deemed rental income on unsold flats was taxable under Section 23(5).

Petitioner’s Arguments

The assessee contended that the additions were based entirely on dumb documents such as unsigned loose sheets, internal excel workings and third-party digital data which did not mention buyers’ names, dates of cash receipt, confirmation of transactions or any evidence of actual cash flow. It was argued that these documents merely reflected offer rates or negotiation proposals and not actual sale consideration. The assessee further submitted that no purchaser was examined, no cash trail or unexplained investment was found, and affidavits from buyers denying any cash payment were ignored. It was also contended that applying a uniform sale rate and estimating profit at 17% was arbitrary.

Respondent’s Arguments

The Revenue relied on the seized material, cost workings and broker data to contend that sale prices shown in registered deeds were below construction cost and that the assessee must have received cash consideration. The Revenue challenged the partial relief granted by the CIT(A) and sought restoration of the AO’s additions. It also argued that deemed rent under Section 23(5) should have been computed at a higher rate.

Court Order / Findings

The ITAT Ahmedabad held that the additions for alleged on-money receipts were unsustainable. The Tribunal observed that the seized documents relied upon by the AO were merely indicative quotations or internal workings and did not constitute proof of actual receipt of cash. No corroborative evidence such as confirmation from buyers, cash flow trail, unexplained investment or utilisation of alleged on-money was found. The Tribunal reiterated that suspicion, however strong, cannot replace evidence, and reliance was placed on judicial precedents including Maulikkumar K. Shah and Fort Projects (P) Ltd.

The Tribunal further held that even the estimation of uniform sale rate at ₹6,500 per sq. ft. by the CIT(A) was based on assumptions and could not be sustained in absence of concrete evidence. Accordingly, the entire additions relating to alleged on-money for both projects were deleted for both assessment years.

On the issue of deemed rent, the Tribunal upheld the applicability of Section 23(5) and confirmed estimation of deemed rental income at 3% of fair market value as reasonable, rejecting the Revenue’s plea for higher rate.

Important Clarification

The Tribunal clarified that in real-estate cases, additions for on-money receipts cannot be made merely on the basis of loose sheets, internal excel files or indicative rates unless supported by independent, corroborative evidence such as buyer confirmations or cash flow. It was also clarified that Section 23(5) applies to unsold flats once the statutory period from obtaining completion certificate expires, irrespective of when construction commenced.

Final Outcome

The appeals filed by the assessee for Assessment Years 2021-22 and 2022-23 were allowed in respect of deletion of on-money additions, while the addition towards deemed rent under Section 23(5) at 3% was upheld. The appeals filed by the Revenue for both years were dismissed in entirety.

Link to download order 

 https://www.mytaxexpert.co.in/uploads/1769061819_DEPUTYCOMMISSIONEROFINCOMETAXCENTRALCIRCLE14AHMEDABADAHMEDABADVS.SKZDEVELOPERSLLPAHMEDABAD.pdf

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