LAKHBIR SINGH,BULANSHAHAR vs. INCOME TAX OFFICER, BULANDSHAHAR

IN THE INCOME TAX APPELLATE TRIBUNAL, DELHI BENCH: “SMC” NEW DELHI BEFORE SHRI SATBEER SINGH GODARA, JUDICIAL MEMBER ITA Nos.3547 to 3549/Del/2026 Assessment Year: 2020-21 to 2022-23 Lakhbir Singh, Vs. Income Tax Officer, H. No. 84, Moh. Ahirpara Bulandshahr Khurja, Bulandshahr PAN: AWKPS4327A (Appellant) (Respondent)

Assessee by Sh. Rajeev Kaushal, CA Department by Sh. Manoj Kumar, Sr. DR

Date of hearing 02.07.2026 Date of pronouncement 02.07.2026 ORDER

These assessee’s three appeals ITA Nos.3547, 3548 & 3549/Del/2026 for assessment years 2020-21, 2021-22 and 2022- 23, arise against the Commissioner of Income Tax (Appeals)/National Faceless Appeal Centre [in short, the “CIT(A)/NFAC”], Delhi’s orders, all dated 22.01.2026, having DINs and orders no. ITBA/NFAC/S/250/2025-26/1085078758(1), 1085084584(1) and 1085084700(1) involving proceedings under

ITA No.3547 to 3549/Del/2026

section 147 of the Income-tax Act, 1961 (hereinafter referred to as ‘the Act’); respectively. Heard both the parties. Case file perused. 2. Learned departmental representative vehemently argues in support of both the learned lower authorities’ respective assessments and lower appellate findings that the assessee/appellant herein has rightly been assessed for having paid on-money of Rs.21 lakhs in both AYs 2020-21 & 2021-22 and Rs. 5,39,500/- in AY 2022-23 to the developer M/s. Omaxe group as per departmental authorities’ action having found/seized the corresponding incriminating material in search action on 14.03.2022. 3. I have given my thoughtful consideration to the assessee’s and the Revenue’s respective vehement submissions against and in support of the impugned addition. There is hardly any dispute between the parties that both the learned lower authorities have more gone by their respective assumptions and presumptions than having discussed any incriminating material indicating the assessee to have made the impugned on-money payments to the searched party in question. It is further emphasized that there is

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ITA No.3547 to 3549/Del/2026

no indication in the assessment order or in the lower appellate discussion discussing any actual evidence against the assessee to buttress the on-money allegation against her. I thus find no merit in the impugned addition of Rs.21 lakhs in both AYs 2020-21 & 2021-22 and Rs. 5,39,500/- in AY 2022-23, which are hereby deleted in very terms. 4. These assessee’ three appeals ITA No.3547 to 3549/Del/2026 are allowed. A copy of this common order be placed in the respective case files. Order pronounced in the open court on 2nd July, 2026 Sd/- (SATBEER SINGH GODARA) JUDICIAL MEMBER Dated: 23rd July, 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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