MOMEE BRAHMA,NEW DELHI vs. INCOME TAX OFFICER, WARD 5(1)(5), NOIDA

IN THE INCOME TAX APPELLATE TRIBUNAL, DELHI BENCH: “SMC” NEW DELHI BEFORE SHRI SATBEER SINGH GODARA, JUDICIAL MEMBER ITA No.2221/Del/2026 Assessment Year: 2020-21 Momee Brahma, Vs. Income Tax Officer, A-188, GAIL Apartment, Ward-5(1)(5), Sector -62, Noida Noida PAN: ALXPB6860D (Appellant) (Respondent) Assessee by Sh. Salil Kapoor, Adv. Ms. Sakshi Rustagi, Adv. Sh. Shivam Yadav, Adv. Department by Sh. Manoj Kumar, Sr. DR Date of hearing 02.07.2026 Date of pronouncement 02.07.2026 ORDER This assessee’s appeal for assessment year 2020-21, 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/250/2025-26/1084037287(1), dated 24.12.2025 involving proceedings under section 147 of the Income- tax Act, 1961 (hereinafter referred to as ‘the Act’). Heard both the parties. Case file perused. 2. Coming to the assessee’s sole substantive ground raised herein, it transpires during the course of hearing that both the

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learned lower authorities’ respective assessment and lower appellate discussion have held the assessee to have invested a sum of Rs.10 lakhs in cash in M/s. Bhutani group of companies. It is made clear that the learned departmental representative appears to have carried out a search action in the alleged recipient group on 04.01.2024. It is on the basis of same alleged material not specified in the assessment or in the lower appellate findings that the impugned addition has been made in the assessee’s hand. 3. Both the parties vehemently reiterate their respective stands against and in support of the impugned addition. This tribunal sought to verify both the assessment as well as lower appellate discussion as to what specific material has been discovered against the assessee so as to add the sum in issue of Rs.10 lakhs in her hands. No such evidence has seen like till date in the department favour. I, therefore, see no merit to uphold the impugned addition of Rs.10 lakhs made in the assessee’s case. Deleted accordingly. 4. This assessee’s appeal is allowed. Order pronounced in the open court on 2nd July, 2026 Sd/- (SATBEER SINGH GODARA) JUDICIAL MEMBER Dated: 27th July, 2026. 2 | P a g e

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RK/- Copy forwarded to: 1. Appellant 2. Respondent 3. CIT 4. CIT(A) 5. DR Asst. Registrar, ITAT, New Delhi

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