SAROJ MEHTA,MOHALI vs. DCIT CC-26, DELHI

IN THE INCOME TAX APPELLATE TRIBUNAL, DELHI BENCH: “SMC” NEW DELHI BEFORE SHRI SATBEER SINGH GODARA, JUDICIAL MEMBER ITA No.3888/Del/2026 Assessment Year: 2017-18 Saroj Mehta, Vs. DCIT, House No.2521, Sector-70, Central Circle-26, Mohali – 160055, New Delhi Punjab PAN: AGEPM4230C (Appellant) (Respondent) Assessee by Sh. P. Roy Chaudhary, Adv. Sh. R.K. Gupta, CA Department by Sh. Manoj Kumar, Sr. DR Date of hearing 02.06.2026 Date of pronouncement 02.06.2026 ORDER This assessee’s appeal for assessment year 2017-18, arises against the Principal Commissioner of Income Tax (Appeals) -31, [in short, the “PCIT(A)”], New Delhi’s order dated 23.03.2026 passed in case no. CIT(A), Delhi-29/10187/2019-20, involving proceedings under section 143(3) of the Income-tax Act, 1961 (hereinafter referred to as ‘the Act’). Heard both the parties. Case file perused. 2. Coming to the assessee’s sole substantive ground raised herein, I notice that she seeks to reverse both the learned lower

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authorities’ respective findings assessing her cash deposits during demonetization period amounting to Rs.29,00,000/- as unexplained under section 68 of the Act; in assessment order dated 18.12.2019 as upheld in the lower appellate discussion. 3. I have given my thoughtful consideration to the assessee’s and the Revenue’s respective vehement submissions. I wish to make it clear that there has been no dispute all along that the assessee is engaged in the business of trading of plywood, veneers, commercial plywood, laminated MDF board and industrial plyboard, where possibility of cash turnover in such an unorganized sector could not be altogether ruled out. And she had filed all the relevant details of the business turnover during demonetization, whose credit could not be denied in entirety, although she appears to have not successfully discharged her onus of pleading and proving her explanation to the very effect. Be that as it may, I thus deem it appropriate in this factual backdrop that a lumpsum addition of Rs.2 lakhs in the assessee’s hands would be just and proper with a rider that the same shall not be treated as a precedent. The assessee gets relief of Rs.27,00,000/-in other words. Necessary computation shall follow as per law.

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