ASSISTANT COMMISSIONER OF INCOME TAX, DELHI vs. SALONI PUNIHANI, DELHI

ITA 3366/DEL/2026Status: DisposedITAT Delhi27 July 2026AY 2020-215 pages
AI SummaryDismissed

What were the facts?

The Assessing Officer (AO) initiated reassessment proceedings under Section 147 based on information about time deposits purchased by the assessee. During reassessment, the AO made an addition of Rs. 90,00,000/- on account of unexplained credit in the bank, claimed as a gift, after the initial reason for reopening (FDRs) was explained by the assessee.

What did the Tribunal hold?

The Tribunal held that the reassessment order was unsustainable as the AO made an addition on a different ground than the one for which the assessment was reopened. Relying on High Court decisions, the Tribunal quashed the reassessment order.

What were the issues?

Whether reassessment proceedings are valid when the addition is made on a ground different from the reason for reopening, and whether the CIT(A) erred in quashing the reassessment based on this discrepancy.

Which sections of the Income-tax Act were involved?

Section 147,Section 148,Section 143(3),Section 69A,Section 115BBE,Section 69(1),Section 56(2)(v)

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, DELHI BENCH ‘A’, NEW DELHI

For Appellant: Shri Suresh Gupta, C.A
For Respondent: Shri Balkishan Gopal, Sr. D.R
Hearing: 27.07.2026Pronounced: 27.07.2026

PER NAVEEN CHANDRA, ACCOUNTANT MEMBER :

The instant appeal filed by the Revenue is directed against the order dated 31.01.2026 passed by the ld. Commissioner of Income-tax (Appeals)-New Delhi [hereinafter referred to as the Ld. CIT(A)] arising out of the Assessment order dated 10.02.2025, passed by the Assessing Officer, DCIT, Central Circle-19, (hereinafter referred as "the AO") u/s 147/143(3) of Income Tax Act, 1961 (hereinafter referred to as "the Act") for the AY 2020-21. 2. Revenue has raised the following grounds of appeal as under: 1 . “Whether on the facts and in the circumstances of the case, Ld. CIT(A) has erred in law and on facts in annulling the reassessment proceedings initiated under section 147 read with section 148 of the

The order continues below.

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