Inconsistent Claims on Seized Cash Lead to Dismissal of Tax Appeal; HC Upholds Rs. 1.42 Lakh Addition
Shantilal Khimjibhai Uchadadia had filed a writ petition in the Gujarat High Court, challenging an order dated October 29, 1999, passed by the Income Tax Appellate Tribunal (ITAT), Ahmedabad. The final decision on the present matter was announced on February 18, 2026, by the Honourable Justice A.S. Supehia and Justice Pranav Trivedi. Through the impugned order, the tribunal had confirmed an addition amounting to Rs. 1,42,450 made by the Income Tax Authorities.
Previously, a search was conducted at the residence of the assessee, where the tax officials found cash amounting to Rs. 677,450. The assessee explained that Rs. 142,450 pertained to his wife and that part of the cash was related to M/s Ohm Developers. However, the Assessing Officer (AO) noted that the assessee was not consistent in his statements. In conclusion, the AO made an addition of the complete amount to the assessee’s income.
When the aggrieved assessee approached the ITAT, the tribunal observed that the assessee had changed his statement regarding the ownership of the cash and also failed at furnishing sufficient proof. He did not produce reliable documents, confirmations, or evidence to establish the creditworthiness of the alleged transactions. Even the persons produced for verification did not confirm taking loans from his wife. The Tribunal therefore upheld the addition made by the AO.
The High Court, when analysing the facts of the case, noted that a similar related appeal filed by the same applicant had already been dismissed in 2012, where similar issues, including the amount of Rs. 1,42,450, were examined. Relying on that earlier decision and agreeing with the Tribunal’s findings, the Court held that no substantial question of law arose in the present case. Accordingly, the High Court answered the questions in favour of the Revenue and dismissed the tax appeal.
Citation: Shantilal Khimjibhai Uchadadia Vs ACIT (Gujarat High Court); R/Tax Appeal No.1805 Of 2010; 18/02/2026
