PARVATI DEVI EDUCATIONAL SOCIETY,NEW DELHI vs. INCOME TAX OFFICER (EXEMPTION), WARD 2(4), DELHI, NEW DELHI

ITA 3654/DEL/2026Status: DisposedITAT Delhi17 July 2026AY 2017-183 pages

In favour of the assessee: the assessee's appeal was allowed. From the AI summary of this appeal.

AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that the cash deposits were explained by student fees, and the books of accounts could not be summarily rejected without specific defects being pointed out. Therefore, both the cash addition and the GP estimation were deleted.

What were the facts?

The assessee, an educational society, had cash deposits of Rs. 13.16 lakhs and its books of accounts were rejected, leading to an estimated GP of 12%. The assessee provided details of students who paid fees in cash, and no specific questions were raised about these deposits.

What were the issues?

Whether cash deposits made by an educational society are unexplained, and whether its books of accounts can be rejected and GP estimated without specific defects being identified.

Which sections of the Income-tax Act were involved?

Section 144,Section 143(3)

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, DELHI BENCH: “SMC” NEW DELHI

Before: SHRI SATBEER SINGH GODARA

Hearing: 01.06.2026Pronounced: 01.06.2026

IN THE INCOME TAX APPELLATE TRIBUNAL, DELHI BENCH: “SMC” NEW DELHI BEFORE SHRI SATBEER SINGH GODARA, JUDICIAL MEMBER I.T.A. No. 3654/Del/2026 Assessment Year: 2017-18 Parvati Devi Educational Vs. Income Tax Officer, Society, 6/88, Paschimi (Exemption) Ward 2(4), Friends EN SP Road, New Delhi Delhi110086, New Delhi PAN: AABTP 4852A (Appellant) (Respondent)

Assessee by Sh. Amarbir Singh Walia, Adv. Department by Sh. Manoj Kumar, Sr. DR

Date of hearing 01.06.2026 Date of pronouncement 01.06.2026 ORDER

This assessee’s appeal for assessment year 2017-18, 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/250/2025-26/1084333712(1), dated 01.01.2026 involving proceedings under section 144 r.w.s. 143(3) of the Income-tax Act, 1961 (hereinafter referred to as ‘the Act’).

Heard both the parties. Case file perused.

ITA No. 3654/Del/2026

The assessee/appellant herein appears to have raised its twin substantive grounds against both the learned lower authorities’ respective findings treating its entire cash deposits of Rs.13.16 lakhs as unexplained followed by rejection of its books and estimation of GP @12% in question. This is what leaves the assessee aggrieved. 3. Both the parties vehemently reiterate their respective stands so far as the former addition of cash deposits is concerned. The Revenue could hardly dispute that this assessee carries out educational activities; and, all a long, it has filed the corresponding details of the students concerned who had paid their fees in cash. There is further no denial to the fact that no specific question has been raised regarding all these cash deposits as coming from the said students. And that the assessee duly placed on record all of their corresponding details in the lower proceedings. The impugned cash addition of Rs.18.16 lakhs stands deleted in entirety therefore. 4. The outcome would hardly to any different regarding the latter issued of GP estimation @12% in the assesse’s case as both the lower authorities have picked up some strong entries that there are

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ITA No. 3654/Del/2026

some cash deposits, cash expenses, in the assessee’s regular activity. This tribunal is of the considered view that the assessee’s books of accounts couldn’t have been summarily rejected as there is no other specific defect pin-pointed regarding its book entries. The impugned GP estimation @ 12% stands deleted.

This assessee’s appeal is allowed.

Order pronounced in the open court on 01.06.2026

Sd/- (SATBEER SINGH GODARA) JUDICIAL MEMBER Dated: 17.07.2026 GP/Sr. PS Copy forwarded to: 1. Appellant 2. Respondent 3. CIT 4. CIT(A) 5. DR Asst. Registrar, ITAT, New Delhi

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