DEEPAK SIROHI,GHAZIABAD vs. ITO, GHAZIABAD

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ITA 7550/DEL/2026Status: DisposedITAT Delhi19 August 2026AY 2012-133 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that the assessee had sufficiently explained the source of the impugned investments. The evidence provided, including bank statements and receipts, remained unrebutted by the revenue.

What were the facts?

The assessee challenged an addition of Rs. 43,85,250/- made by the revenue as unexplained investment in property. The assessee provided evidence of loans received, motor car sale receipts, and agricultural income to explain the source of these investments.

What were the issues?

Whether the investments made by the assessee in property were unexplained and thus liable for addition under Section 69 of the Income Tax Act.

Which sections of the Income-tax Act were involved?

Section 69,Section 143(3),Section 147

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, DELHI BENCH: “SMC” NEW DELHI

Before: SHRI SATBEER SINGH GODARA

Hearing: 19.08.2026Pronounced: 19.08.2026

IN THE INCOME TAX APPELLATE TRIBUNAL, DELHI BENCH: “SMC” NEW DELHI BEFORE SHRI SATBEER SINGH GODARA, JUDICIAL MEMBER

ITA No. 7550/Del/2026, A.Y. 2012-13 Vs. Deepak Sirohi Income Tax Officer, 2/2, Sector-2, Rajendera Ward 2(1)(2), Nagar, New Delhi Sahibabad, Ghaziabad PAN: AGQPS8314P (Appellant) (Respondent)

Assessee by Sh.Rajat Garg, CA Department by Sh. Manoj Kumar, Sr. DR

Date of hearing 19.08.2026 Date of pronouncement 19.08.2026

ORDER This assessee’s appeal for assessment year 2012-13, 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/250/2025-26/1084050493(1), dated

ITA No. 7550/Del/2026

24.12.2025 involving proceedings under section 143(3) r.w.s. 147 of the Income-tax Act, 1961 (hereinafter referred to as ‘the Act’).

Heard both the parties. Case file perused.

2.

Delay of 146 days in filing of the assessee’s instant appeal is condoned in larger interest of justice and in light of Collector, Land & Acquisition vs. Mst. Katiji & Others (1987) 167 ITR 471 (SC).

3.

Learned counsel canvasses the assesse’s sole substantive ground on merits challenging the learned lower authorities’ action making section 69 unexplained investment(s) in property (ies) amounting to Rs. 43,85,250/- which forms the sole subject matter for the tribunal’s apt adjudication herein.

3.

That being the case, the assesse invites the tribunal’s attention to the loans received from Sri Anshul Jain, Sh. Anil Kumar involving Rs. 23.90 lacs and 4,00,000/- followed by motor car sale receipts of Rs. 6 lacs and agricultural income of Rs. 18,98,500/-, respectively all duly supported by the corresponding bank statements, repayments, receipts and “J” - form which have gone unrebutted from the Revenue side. I hold in these facts and circumstances that

ITA No. 7550/Del/2026

the assesse has very well explained the source of his impugned investments amounting to Rs. 43.85 lacs and the same could not have been treated as unexplained by learned departmental authority. The impugned additions is directed to be deleted therefore.

4.

The assessee’s appeal is allowed.

Order pronounced in the open court on 19/08/2026

Sd/- (SATBEER SINGH GODARA) JUDICIAL MEMBER Dated: 02.09.2026 Binita, Sr. PS Copy forwarded to: 1. Appellant 2. Respondent 3. CIT 4. CIT(A) 5. DR Asst. Registrar, ITAT, New Delhi

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