JAI PRAKASH SINGHAL,DELHI vs. THE DEPUTY COMMISSIONER OF INCOME TAX, DELHI

IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH, A: NEW DELHI BEFORE SHRI SATBEER SINGH GODARA, JUDICIAL MEMBER AND SMT. RENU JAUHRI, ACCOUNTANT MEMBER ITA No.- 1898/Del/2026 [Assessment Year: 2020-21] Jai Prakash Singhal, Deputy Commissioner of Income H. No. 63, third floor, Pocket-19, Tax, Block-F, Sector-8, Rohini, New Vs Central Circle 18, NCC DIT(S), Delhi-110085. Jhandewalan Ext. New Delhi-110055. PAN- ANVPS5260Q Assessee Revenue Assessee by Sh. Nagesh Behl, CA Revenue by Ms. Pooja Swaroop, CIT(DR) Date of Hearing 20.07.2026 Date of Pronouncement 20.07.2026 ORDER Per Renu Jauhri, Accountant Member:

This appeal by the assessee is directed against the order dated 26.12.2025 of the Ld. Commissioner of Income Tax (Appeals)-27, New Delhi [hereinafter referred to as the ‘Ld. CIT(A)] arising out of the Assessment Order dated 28.03.2025 passed under section 147/143(3) of the Income Tax Act, 1961 (hereinafter referred to as ‘the

ITA No.- 1898/Del/2026 Jai Prakash Singhal Act’) by the DCIT/ACIT, Central Circle-18, New Delhi, (hereinafter referred to as the ‘AO’) pertaining to Assessment Year (A.Y.) 2020-21. 2. The assessee has raised the following grounds of appeal:

“ 1. That Id. CIT (A) erred in deciding appeal filed by the Appellant without giving opportunity of being heard. 2. That Sanction u/s 151 of the Act is void and improper, in the entire sanction no amount or assessment year or incriminating material is mentioned which is alleged to be escaped assessment. a. The approval u/s 151 is void and improper as the same is mechanical and without application of mind. 3. That assessment u/s 143(3) r/w 147 is bad in law as no notice u/s 148 was uploaded on the website of the income tax department and also wrong email ID is mentioned on the income tax department's website, thus notice u/s 148 is void 4. That assessment u/s 143(3) r/w 147 is bad in law as no notice u/s 143(2) was uploaded on the website of the income tax department and also wrong email ID is mentioned on the income tax department's website, thus notice u/s 143(2) is void. 5. The Ld. AO erred in making addition without supplying certificate u/s 65B of the Indian Evidence Act, 1872 in respect of electronic documents/devices. 6. The Ld. AO erred in making addition without supplying complete relied upon material including Full statements, Complete digital evidence, Investigation reports, Bank trail analysis relied upon. 7. The Ld. AO erred in making addition without giving opportunity of cross- examination of alleged third parties (including alleged operators/directors of other entities) was provided. 8. The Ld. AO erred in making additions of Rs.2,80,56,007 u/s 69A of the Act a. The Ld. AO failed to appreciate that the bank deposits cannot be treated as income in entirety, no independent verification was carried out. b. The Ld. AO erred in making addition solely on the basis of statement recorded u/s 132(4) without corroborative evidence and without giving regard to the retraction filed by the assessee. It is settled law that statement alone, without corroborative material, cannot justify addition9. The Ld. AO erred in making additions of Rs. 11,88,20,180 u/s 690 of the Act 2

ITA No.- 1898/Del/2026 Jai Prakash Singhal

a. The Ld. AO failed to appreciate that the bank deposits cannot be treated as income in entirety, no independent verification was carried out. b. The Ld. AO erred in making addition solely on the basis of statement recorded u/s 132(4) without corroborative evidence and without giving regard to the retraction filed by the assessee. It is settled law that statement alone, without corroborative material, cannot justify addition 10. The appellant craves leave to add to or amend the aforesaid grounds before disposal of the appeal”

Sd/- Sd/- [SATBEER SINGH GODARA] [RENU JAUHRI] JUDICIAL MEMBER ACCOUNTANT MEMBER Dated- 24.07.2026. Pooja, Sr. PS. 3

ITA No.- 1898/Del/2026 Jai Prakash Singhal Copy forwarded to: 1. Assessee 2. Respondent 3. CIT 4. CIT(A) 5. DR

Asst. Registrar, ITAT, New Delhi,