ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-19, DELHI, DELHI vs. MANOJ VASUDEO PARDASANY (HUF), MUMBAI

IN THE INCOME TAX APPELLATE TRIBUNAL, DELHI BENCH: ‘E’ NEW DELHI BEFORE SHRI SATBEER SINGH GODARA, JUDICIAL MEMBER AND SHRI NAVEEN CHANDRA, ACCOUNTANT MEMBER ITA No.7887/Del/2025 Assessment Year: 2022-23 ACIT, Vs. Manoj Vasudeo Pardasany Central Circle-19, (HUF), Delhi 5, Bharti B, Sherly Rajan Road, Bandra-west, Mumbai PAN: AALHM9622F (Appellant) (Respondent) Assessee by None Department by Ms. Ankush Kalra, Sr. DR Date of hearing 12.05.2026 Date of pronouncement 10.08.2026 ORDER PER SATBEER SINGH GODARA, JM This Revenue’s appeal for assessment year 2022-23, arises against the Commissioner of Income Tax (Appeals)-27 [in short, the “CIT(A)”], New Delhi’s order dated 26.08.2025 passed in case no. CIT(A), Delhi -27/10113/2021-22, involving proceedings under section 143(3) of the Income-tax Act, 1961 (hereinafter referred to as ‘the Act’).

ITA No.7887/Del/2025

Case called twice. None appears at the assessee/respondent’s behest. It is accordingly proceeded ex-parte. 2 The Revenue raises the following substantive grounds in the instant appeal: “1. Whether on the facts and circumstances of the case, L. CIT(A) has erred in deleting the addition of Rs. 82,14,890/- made by the Assessing Offteer by rejecting the books of account under section 145(3) of the Act and estimating income @12% on the basis of investigation findings, admission under statements recorded on oath and corroborative evidences? 2 Whether on the facts and circumstances of the case, Ld. CIT(A) has erred in law and on facts in accepting the books of account of the assessee despite clear findings from the search proceedings, third- party statements, and failure of the assessee to produce corroborative documentary evidence such as work orders, deliverables, and confirmations to substantiate the alleged consultancy services rendered? 3. Whether on the facts and circumstances of the case, Ld. CIT(A) has failed to appreciate that the documents relied upon by the assessee (invoices, ledgers, confirmations) are in the nature of self-serving documents and are commonly used in accommodation entry cases to create a façade of genuineness? 4. Whether on the facts and circumstances of the case, Ld. CIT(A) erred in igrioring the fact that the statement recorded on oath of the Karta of the assessee-HUF, Shri Manoj Vasudev Pardasany, wherein he admitted to involvement in generating accommodation entries, routing of funds, and siphoning of cash through bogus consultancy contracts? 5. Whether on the facts and circumstances of the case, Ld. CIT(A) has erred in holding that each assessment year is separate without considering that a consistent and systematic modus operandi for tax evasion was clearly established in this and earlier years through corroborative evidence and findings of the investigation. 6. Whether on the facts and circumstances of the case, Ld. CIT(A) failed to consider that estimation of income at 12% was not arbitrary but based on the modus operandi uncovered during the search, 2 | P a g e

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corroborated by material on record and followed consistently in earlier assessments of the assessee? 7. (a) The order of L.d. CIT (A) is erroneous and not tenable in law and on facts. (b) The appellant craves leave to add, alter or amend any/all of the grounds of appeal before or during the course of the hearing of the appeal.”

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Order pronounced in the open court on 10th August, 2026 Sd/- Sd/- (NAVEEN CHANDRA) (SATBEER SINGH GODARA) ACCOUNTANT MEMBER JUDICIAL MEMBER Dated: 10th August, 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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