Unaccounted "On-Money" Cash Receipts from Property Deals Taxable at 45% Profit Margin Under Section 148

The ITAT upheld that unaccounted cash receipts ("on-money") discovered during seizure operations constituted taxable income despite subsequent property registration to other parties. The Tribunal rejected the assessee's claim to reduce Rs. 10,00,000 from the addition as the CIT(A) found only the payment method had changed, not the total amount. However, regarding taxation of cash receipts, the ITAT modified the CIT(A)'s 50% profit estimation to 45% of gross receipts, partially allowing the assessee's appeal. The Tribunal confirmed the validity of notice under section 148 without providing 7 days to reply under section 148A(b) since search and seizure operations were conducted after 01.04.2021, making the case exempt from section 148A requirements per the proviso. .....

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