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Income Tax Appellate Tribunal - Delhi

Pawan Kumar Laur,Uttarpradesh vs Ito Ward -2 (3) (2), Bulandshahar on 9 February, 2026

         IN THE INCOME TAX APPELLATE TRIBUNAL,
              DELHI BENCH: "SMC" NEW DELHI

 BEFORESHRI SATBEER SINGH GODARA, JUDICIAL MEMBER

                     ITA No.154/Del/2026
                   Assessment Year: 2022-23
Sh. Pawan Kumar Laur,        Vs. Income Tax Officer,
B-706, ITBP Society, Sector      Ward-2(3)(2),
PIE    -1,  Greater   Noida,     Bulandshahar,
Gautam Buddha Nagar,             Uttar Pradesh
Uttar Pradesh
PAN: AAPPL9503Q
         (Appellant)                     (Respondent)

           Assessee by       Sh. Mukesh Kumar Jain, CA
                             Sh. Samayak Jain, Adv.
           Department by     Sh. Manoj Kumar, Sr. DR

                         Date of hearing                 09.02.2026
                         Date of pronouncement           09.02.2026

                              ORDER

This assessee's appeal for assessment year 2022-23, arises against the Commissioner of Income Tax (Appeals)/National Faceless Appeal Centre [in short, the "CIT(A)/NFAC"], Delhi's DIN and order no. ITBA/NFAC/S/250/2025-26/1083072449(1), dated 27.11.2025 involving proceedings under section 143(3) of the Income-tax Act, 1961 (hereinafter referred to as 'the Act').

Heard both the parties. Case file perused.

2. It emerges during the course of hearing that both the learned lower authorities' respective assessment and lower ITA No.154/Del/2026 appellate discussion/findings dated 06.03.2024 and 27.11.2025 have held the assessee's cash deposits in the relevant previous year to the tune of Rs.32.20 lakhs as unexplained under section 69A of the Act which forms the sole substantive issue of adjudication in the instant appeal. Both the parties vehemently reiterate their respective stands against and in support of the impugned addition. Learned counsel has invited the tribunal's attention to the assessee's twin bank accounts cash flows wherein he is stated to have withdrawn Rs.38.25 lakhs in FY 2020-21 from SBI bank account and again Rs.8.85 lakhs in the relevant previous year. His case therefore is that the impugned cash deposits of Rs.32.20 lakhs represent his previous cash withdrawals only which have not been successfully proved to the entire satisfaction of both the lower authorities.

3. Be that as it may, this tribunal sees only a part merit in the assessee's case going by his previous withdrawals and his impugned cash deposits. It is thus deemed appropriate in the larger interest of justice that a lumpsum addition of Rs.2.20 lakhs in the hands of the assessee is deemed just and proper with a

2|Page ITA No.154/Del/2026 rider that the same shall not be treated as a precedent. The assessee gets relief of Rs.30 lakhs in other words.

4. This assessee's appeal is partly allowed.

Order pronounced in the open courton9th February, 2026 Sd/-

(SATBEER SINGH GODARA) JUDICIAL MEMBER Dated: 25th February, 2026.

RK/-

Copy forwarded to:

1. Appellant
2. Respondent
3. CIT
4. CIT(A)
5. DR Asst. Registrar, ITAT, New Delhi
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