M/S NAWLA ISPAT PVT. LTD.,SARDHANA vs. DCIT, CENTRAL CIRCLE, MEERUT, MEERUT

IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH, G: NEW DELHI BEFORE SHRI ANUBHAV SHARMA, JUDICIAL MEMBER AND SMT. RENU JAUHRI, ACCOUNTANT MEMBER ITA No.- 1515/Del/2026 [Assessment Year: 2019-20] M/s Nawla Ispat Pvt. Ltd., DCIT, Opp. Power House, Meerut Road, Central Circle, Sardhana, Uttar Pradesh-250342. Vs Meerut, Aayakar Bhawan, New Bhainsali Ground Delhi Road, Meerut, Uttar Pradesh-250002. PAN- AACCN8595N Assessee Revenue Assessee by Shri Rohit Agarwal, CA Revenue by Shri Lalit Mohan Jindal, CIT(DR) Date of Hearing 05.08.2026 Date of Pronouncement 09.09.2026 ORDER Per Renu Jauhri, Accountant Member:

This appeal by the assessee is directed against the order dated 16/09/2025 of the Ld. Commissioner of Income Tax, (Appeal)-3, ARTO Complex, 2nd floor, Sector- 33, Noida, [hereinafter referred to as the ‘Ld. CIT(A)] arising out of the Order dated 26.03.2024 passed under section 153C r.w.s. 143(3) of the Income Tax Act, 1961 (hereinafter referred to as ‘the Act’) by Deputy Commissioner of Income Tax,

ITA No.- 1515/Del/2026 M/s Nawla Ispat Pvt. Ltd. Central Circle, Meerut, (hereinafter referred to as the ‘AO’) pertaining to Assessment Year (A.Y.) 2019-20. 2. The Assessee has raised the following grounds of appeal:

“ 1. That the Ld. CIT(A) has erred in law and facts of the case in confirming the addition of Rs.2,57,115/-, only on the basis of the books of M/s World Window Impex Group, without considering the submissions made by the appellant in right perspective. 2. That the Ld. CIT(A) has erred in law and facts of the case in confirming the addition of Rs.2,57,115/- made by the Ld. A.O. u/s 68 of the Act, u/s 69A of the Act, as the same cannot be treated as unexplained credit or undisclosed investment in the hands of the appellant. 3. That the appellant respectfully craves leave to add alter omit or substitute any or all of the above grounds of appeal at any time before or at the time of hearing of appeal to enable your good self to decide the appeal in accordance with law.”

ITA No.- 1515/Del/2026 M/s Nawla Ispat Pvt. Ltd. M/s World Window Group, after 31.03.2013 i.e. after FY 2012-13 and is not aware as to how and why this amount of Rs. 2,57,115/- was outstanding to its credit in the alleged parallel books found during the course of search. The proceedings u/s 153C/143(3) of the Act, were completed vide order dated 26.03.2024 wherein the A.O. made addition of Rs.2,57,115/- holding that the same represented unaccounted income of the assessee.

3.1 Aggrieved, the assessee preferred an appeal before the CIT(A), who dismissed the same vide order dated 16.09.2025. Further aggrieved, the assessee is in appeal before the Tribunal.

ITA No.- 1515/Del/2026 M/s Nawla Ispat Pvt. Ltd. transaction was undertaken by the assessee and it is not understood how an opening balance of Rs. 2,57,115/- as on 1.4.2018 had been shown against the assessee’s name in the trial balance. Further, from the seized documents, it is not clear as to in which year the impugned transaction had taken place. There is no other detail or document made available to the assessee and, therefore, assessee cannot be expected to explain the alleged transaction. Ld. AR has further argued that in the absence of details such as the date of transaction, manner/mode of receipt/ payment etc., the impugned amount cannot be treated as unexplained cash credit or investment merely on the basis of a dumb document found during the course of search conducted on a third party.

ITA No.- 1515/Del/2026 M/s Nawla Ispat Pvt. Ltd. details or documentary evidence regarding the nature and date of the alleged transaction undertaken by the assessee with the searched entity during the year under consideration. Even if it is taken as the correct opening balance as on 1.4.2018, there is no justification to add this amount in the year under consideration without ascertaining the nature and actual date of the transaction.

In view of above factual matrix, we are of the considered view that in the absence of relevant details regarding date and nature of the alleged transaction, there is no justification for the AO to make the impugned additions in the hands of the assessee. Accordingly, the addition of Rs. 2,57,411/- made u/s 68 of the Act, by the AO and confirmed by the CIT(A) u/s 69A of the Act is hereby directed to be deleted.

Order pronounced in the open court on 09.09.2026

Sd/- Sd/- [ANUBHAV SHARMA] [RENU JAUHRI] JUDICIAL MEMBER ACCOUNTANT MEMBER Dated- 09.09.2026. Pooja. Copy forwarded to: 1. Assessee 2. Respondent 3. CIT 4. CIT(A) 5. DR

ITA No.- 1515/Del/2026 M/s Nawla Ispat Pvt. Ltd.

Asst. Registrar, ITAT, New Delhi,

1 Date of dictation of Tribunal order 03.09.26 2. Date on which typed draft order is placed before 03.09.26 the dictating Member 3 Date on which typed draft order is placed before the other Member (in the case of DB) 4. Date on which the approved draft order comes to P.S/Sr.P.S 5. Date on which the fair Order is placed before the dictating Member for sign 6. Date on which the fair Order is placed before the other Member for sign ( in the case of DB) 7. Date on which the Order comes back to P.S./Sr.P.S for uploading on ITAT website Date of uploading, if not, reason for not 8. uploading 9. Date on which the file goes to the Bench Clerk 10. Date on which order goes for xerox 11. Date on which order goes for endorsement 12. Date on which the file goes to the Superintendent/O.S. for checking 13. Date on which the file goes to the Assistant Registrar for signature on the order 14. Date on which the file goes to dispatch section for dispatch the Tribunal Order 15. Date of dispatch of order Date on which file goes to Record Room after 16. dispatch the order