RANBIR SINGH,ROHTAK vs. ITO WARD-5, ROHTAK

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ITA 3397/DEL/2026Status: DisposedITAT Delhi13 August 2026AY 2020-213 pages

In favour of the assessee: the assessee's appeal was allowed. From the AI summary of this appeal.

AI SummaryAllowed

What did the Tribunal hold?

The Tribunal condoned the delay in filing the appeal before the CIT(A) as the explanation was found to be genuine. Upon reviewing the evidence, the Tribunal found that the cash payment was supported by documents and bank statements, establishing its bonafide.

What were the facts?

The assessee's case was reopened under Section 147 based on information regarding a cash payment of Rs. 2,85,100/-. The addition made by the AO was confirmed by the CIT(A) who dismissed the assessee's appeal due to a delay.

What were the issues?

Whether the addition of cash payment is justified when supported by evidence, and whether the delay in filing the appeal before the CIT(A) should be condoned.

Which sections of the Income-tax Act were involved?

Section 147,Section 148,Section 250

AI-generated summary — verify with the full judgment below

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

Before: MS MADHUMITA ROY

For Appellant: CA (VC)
For Respondent: Shri Manoj Kumar, Sr. DR
Hearing: 13/08/2026Pronounced: 13/08/2026

INCOME TAX APPELLATE TRIBUNAL DELHI BENCH “SMC”: NEW DELHI BEFORE MS MADHUMITA ROY, JUDICIAL MEMBER ITA No. 3397/Del/2026 (A.Y 2020-21) Ranbir Singh Vs. ITO H No. 374/4, Surya Nagar, Ward-5 gohana road, Rohtak, Aaykar Bhawan, 124001, Rohtak, Haryana Rohtak, Haryana (Appellant) (Respondent) PAN: AZHPR8892H

Assessee by : Sh. Naveen Kumar Goyal, CA (VC) Revenue by: Shri Manoj Kumar, Sr. DR

Date of Hearing 13/08/2026 Date of pronouncement 13/08/2026 O R D E R PER MADHUMITA ROY, J. M.: The instant appeal filed by the assessee is directed against

the order dated 17.03.2026 passed by the Ld. Commissioner of

Income-tax (Appeals)/National Faceless Appeal Centre, Delhi

[hereinafter referred to as the Ld. CIT(A)/NFAC] under Section

250 of the Income Tax Act, 1961 (hereinafter referred to as ‘the

Act’) arising out of the Assessment Order dated 23.03.2025

passed by the Assessment Unit, Income-tax Department under

Section 147 of the Act, for Assessment Year 2020-21.

2.

On the basis of search conducted in the Omaxe Group on

14.03.2022 information received from the Investigation Wing of cash

payment made to the tune of Rs. 2,85,100/- by the Assessee, the

2 ITA No. 3397/Del/2026 Ranbir Singh Vs. ITO case was reopened under Section 147 of the Act by issuing notice

under Section 148of the Act.

3.

In the absence of valid document the impugned amount of

cash payment made by the Assessee was added in the hands of the

Assessee which was further confirmed by the First Appellate

Authority.

4.

Heard the parties and perused the records. It appears that

there was 118 days delay in preferring the appeal before the Ld. First

Appellate Authority explanation whereof was not found to be

acceptable and, therefore, the Ld. CIT(A) dismissed the Appeal

preferred by the Assessee without condoning the delay. Hence, the

instant appeal before us.

5.

The written submission filed by the Assessee before the

authorities below contains the delay application perusal of which the

reason assigned by the Assessee for not been able to file the appeal

on time is found to be genuine and thus, the delayin such filing of

appeal before the Ld. CIT(A) is condoned. Having regard to the

amount of addition in question and the issue involved therein, it is

found to be appropriate to decide the issue itself here instead of

sending the matter before the authorities below. On this context,

this Bench has perused the entire set of documents annexed to the

paper book filed before the authorities belowwherein the impugned

3 ITA No. 3397/Del/2026 Ranbir Singh Vs. ITO cash payment made by the Assessee to the tune of Rs. 2,85,100/-

has been properly supported by evidences including the source

thereof. Relevant to mention that such payment was made for the

purchase of property by the Assessee documents being the bank

statements, including the details of payment made through banking

channel along with all details, establish the bonafide of the Assessee

in making cash payment. Therefore, under this facts and

circumstances of the matter the addition is found to be wrongly

made in the hands of the Assessee and thus, the impugned addition

is deleted.

6.

In the result, appeal of the Assessee is allowed.

Order pronounced in the open court on 13/08/2026.

Sd/- (MADHUMITA ROY) JUDICIAL MEMBER Dated: 13/08/2026 R. Naheed, Sr PS Copy forwarded to

1.

Applicant 2. Respondent 3. CIT 4. CIT (A) 5. DR:ITAT ASSISTANT REGISTRAR ITAT, New Delhi

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