INCOME TAX OFFICER, SIRHIND vs. CHESTA DAHRA, BASSI PATHANA

आदेश / O R D E R Manoj Kumar Aggarwal (Accountant Member) 1. Aforesaid appeal by revenue for Assessment Year (AY) 2022-23 arises out of an order of learned Commissioner of Income Tax (Appeals), NFAC [CIT(A)] dated 10-11-2025 in the matter of an assessment framed by Ld. Assessing Officer [AO] u/s 143(3) r.w.s. 144B of the Act on 27-03-2024. Having heard rival submissions, the appeal is disposed-off as under. The sole issue that arises for our

consideration is addition of Rs.91,14,916/- on account of capital introduction which has been deleted by Ld. CIT(A). 2. The Ld. AO made impugned addition on the allegation that addition of capital could not be substantiated by the assessee with documentary evidences. Accordingly, the impugned addition was made u/s 68 r.w.s. 115BBE. The Ld. CIT(A), after considering the assessee’s submissions, rendered factual finding that the said capital was introduced out of sale proceeds of the shares held by the assessee as investment as on 31.03.2021. The assessee had investment of Rs.58.73 Lacs as on 31.03.2021 which was liquidated for Rs.79.28 Lacs during the year. In support, the assessee filed ledger statement of Zerodha. The assessee also received Rs.9.21 Lacs from her spouse and had salary savings of Rs.7 Lacs. In support, the assessee duly furnished bank statement and Income Tax Return of the spouse. Finding the same to be acceptable evidences, the impugned addition was deleted by Ld. CIT(A) against which the revenue is in further appeal before us. 3. The prime argument of revenue is that the documents filed by the assessee during first appeal were not confronted to Ld. AO. However, Ld. AR amply demonstrated that no new documents were filed during first appeal and all the documents were already made available to Ld. AO. In fact, Ld. AO issued notice u/s 133(6) to Zerodha and called for various documents pertaining to the assessee. The holding statement, ledger, trade book etc. was duly provided to Ld. AO in response to the same. The said position could not be controverted before us. This

being so, the revenue could be said to have no grievance considering the factual findings rendered by Ld. CIT(A). 4. In another ground of appeal, revenue contest allowance of deduction under Chapter VI-A for Rs.1,87,500/-. Upon perusal of para- 7 of impugned order, it could be seen that Ld. CIT(A) has merely directed Ld. AO to allow deduction u/s 80C after due verification. Therefore, the same could not be faulted with. 5. The appeal stand dismissed. Order pronounced on 14th July, 2026

-Sd- -Sd- (LALIET KUMAR) (MANOJ KUMAR AGGARWAL) JUDICIAL MEMBER ACCOUNTANT MEMBER AS Dated: 14-07-2026 आदेश की �ितिलिप अ�ेिषत /Copy of the Order forwarded to : 1. अपीलाथ�/Appellant 2. ��थ�/Respondent 3. आयकरआयु�/CIT 4. िवभागीय�ितिनिध/DR 5. गाड�फाईल/GF

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ITAT CHANDIGARH