DCIT, CENTRAL CIRCLE-17, DELHI vs. PARVINDER SINGH TANEJA, DELHI

Since all the appeals filed by the assessee and the Revenue are having common, identical and similar issues, therefore, they are decided by a common order.

First we take appeal of the assessee in ITA No. 5651/Del/2025 and appeal of the Revenue in ITA No. 8028/Del/2025 for Assessment Year 2019-20.

Brief facts of the case are that the assessee is an individual and e-filed his return of income on 19.08.2019, declaring total income at INR 31,32,020/-. A search and seizure action was carried out on 31.10.2022 at the business premises of Kapoor Watch Company Pvt. Ltd. and its key Associates. The assessee is handling the showroom of Kapoor Watch at Ambience Mall at Gurugram and closely related to the group, his residence situated at C-27, Sushant Lok, Phase-1, Gurugram was also searched. During the course of search, various loose papers/documents were found and seized. Based on the loose papers found during the course of search, case of the assessee was re-opened and notice u/s 148 was issued on 12.03.2024 after taking approval from Competent Authority. In response, assessee filed his return of income on 13.04.2024, declaring same income as was declared in the original return of income filed. During the course of search, certain incriminating material were found including WhatsApp Chat according to which, assessee has sent cash to his father-in-law residing at Dubai who sent back the same to the bank account of assessee and his wife in the form of gifts. AO accordingly, treated the entire gifts received during the year from father-in-law of INR 89,50,000/- as bogus and unexplained money of the assessee received in the guise of gifts and made addition u/s 69A of the Act. Besides this, AO observed that during the year under consideration, assessee has incurred expenditure in cash on the construction of property at C-21, Sushant Lok, Phase-1, Gurugram where cash payments were made to the Directors of M/s. ENN V ENN Designs Pvt. Ltd. and based on the Excel Sheets taken from the data found from the possession of employees of said company, AO concluded that assessee has paid INR 16,18,460/- in cash and accordingly, made the addition u/s 69B of the Act of the same. The total income of the assessee was thus assessed at INR 1,37,00,480/-.

Against the said order, assessee preferred appeal before Ld. CIT(A) who vide order dated 13.08.2025, deleted the additions made on account of alleged cash expenditure incurred on the construction of house property and out of the total addition of INR 89,50,000/- made on account of gifts alleged as bogus, addition of INR 64,50,000/- stood deleted and remaining addition of INR 25,00,000/- is sustained by Ld. CIT(A). Page | 3

Aggrieved by the said order, both parties are in appeal before the Tribunal.

Ground of appeal Nos. 1 to 3 raised by the assessee are with respect to the validity of re-opening of the assessment u/s 147 of the Act however, before us no effective submission was made, therefore the Grounds of appeal Nos. 1 to 3 raised by the assessee are dismissed.

Ground of appeal No.4 raised by the assessee is with respect to the confirmation of addition of INR 25 Lakhs made u/s 69A/115BBE of the Act as alleged unaccounted unexplained money of the assessee. The revenue in Grounds of appeal No. 1 & 2 has \challenged the deletion of addition of Rs. 64,50,000/- made by the Ao u/s 69A/115BBE towards the gifts received from father-in-law held as bogus. Since the issue if common thus the grounds of appeal taken by the assessee and revenue are taken together.

Heard the contentions of both the parties at length and perused the material on record. It is observed that the AO has made the additions by alleging that assessee has received the gifts from his father-in-law who is residing at Dubai and as per WhatsApp Chat found, assessee has sent cash to his father-in-law and received back the same in the guise of gifts. The AO thus alleged that these gifts were received by the assessee out of his unaccounted money generated through property transactions, selling out of books luxury watches in gray market and undisclosed commission income generate by providing entries to M/s Kapoor Watch Company in lieu of cash sales through dummy buyers.

In this regard, it is observed that all the gifts were duly credited in the bank account of the assessee which is forming part of regular books of accounts of assessee based on which return of income was filed by the assessee for the year under appeal. Further the allegation of AO that assessee has generated unaccounted money through property transaction is not correct that since there was no such income whatsoever, was alleged as received from the property transactions found as a result of search or for which any addition was made in the year under appeal. Further, the issue of undisclosed commission income generated by providing entries to Kapoor Watch Company in lieu of cash sales, it is observed that while deciding the revenue’s appeals for various assessment years in the case of Kapoor Watch Company Pvt.Ltd. vs DCIT in ITA Nos. 6825/Del/2025 & others, vide order dt. 29.04.2026, it is held by the Co-ordinate bench that no such cash sales were ever made by M/s Kapoor Watch Company which was routed back as RTGS in the guise of sales and addition made u/s 69C of the Act as commission in the hands of the Kapoor Watch Company stood was deleted. Therefore, this allegation of the AO has no legs to stand. Thus, there is no source of generating undisclosed income as alleged by the AO remained.

Now coming to the issue, whether additions for such alleged gifts could be made under s. 69A of the Act, it is observed that Page | 5 provisions of section 69A could be invoked when the assessee is found to be the owner of any money, bullion or jewellery or other valuable article and same is not recorded in the books of accounts maintained and the source thereof is not satisfactorily explained in the opinion of the AO. In the instant case, as observed above, the gifts received from the father-in-law of the assessee were duly credited in regular bank accounts of the assessee which is forming part of the books of accounts maintained therefore, it cannot be said that these gifts are not recorded in the books of accounts. Moreover, admittedly, the source of the same is from the father-in-law of the assessee who is NRI therefore, no doubts could be raised for the source of said gifts. The ld. CIT(A) has appreciated these facts and after examining the provisions of section 69A and further observing that with respect to the gifts of Rs. 64,50,000/- no evidence of cash remittance was found, deleted the addition to this extent. The final conclusion drawn by ld. CIT(A) in para 4.1 and 4.14 of the order is reproduced as under:

Regarding the addition of Rs. 25.00 lacs confirmed by ld. CIT(A), as observed above, the AO alleged that assessee has earned undisclosed income from property transactions and cash sales of the luxury watches however, no such allegations are without any corroborative material and made on mere assumptions and presumptions. The AO further observed that assessee has admitted this fact in the statements recorded however, such statements are not corroborated by any evidences. The assessee has filed the copies of the bank statements of the donor alongwith his affidavit and it is not the case of the revenue that cash was deposited prior to remittance to the assessee of the gift. The assessee also explained the source of income in the hands of the donor who is NRI and residing out of India since past long. Therefore, the sources in the hands of eh donor cannot be doubted merely on the basis of some WhatsApp chats which do not mention that the sum was send by the assessee which was received back as gift more particularly when no cash was deposited in the bank account of the donors. Only evidence is the statement of the assessee which was retracted later on thus the same cannot be made the sole basis for holding the gifts received as ingenuine.

In view of the above facts and discussion, we are of the considered view that no addition could be made in the hands of the assessee on account of genuine gifts received from his father-in-law. Accordingly, we hereby, deleted the additions upheld by ld. CIT(A) of Rs. 25.00 lacs u/s 60A of the Act. Further since we have already held the gifts received by the assessee as genuine, the order of ld. CIT(A) in deleting the addition of Rs. 64,50,000/- is hereby upheld. Accordingly, Ground of appeal No.4 raised by the assessee is allowed and grounds of appeal No. 1 & 2 of the revenue are dismissed.

Ground of appeal No.5 of the assessee is regarding the validity of the approval granted u/s 148B of the Act. Before us, no effective arguments were made by the ld. AR of the assessee, therefore, this ground of appeal is hereby dismissed.

Ground of appeal Nos. 3 & 4 of the revenue are with respect to the deletion of the addition made of 16,18,460/- u/s 69B of the Act towards unexplained made on the construction of immovable property.

Heard the parties and perused the material available on record. Addition of the similar nature was made in the hand of M/s Kapoor Watch company in AY 2022-23 wherein the AO based on the Excel sheets found from the possession of employees of the contractor M/s ENN V ENN, alleged that the assessee has made cash payment in construction of property. In the instant case also based on the Excel Sheets found from the possession of the same employee of M/s ENN V ENN Design, the AO alleged that assessee has made the cash payments in construction of property and the addition for the same. In the case of Kapoor Watch Company Pvt.Ltd., the Co-ordinate Delhi Bench of Tribunal, in ITA No.5640/Del/2025 & Others vide its order dated 29.04.2026 has confirmed the order of ld. CIT(A) deleting the addition made by making following observations in para 57 to 62 of the order:- 57. “However, there are two new issues in the appeal of the Revenue wherein Revenue has challenged the deletion of addition of INR 1,16,90,723/- on account of cash payment for construction of property and challenged the deletion of addition of INR 51,80,000/- made u/s 56(2)(viib) of the Act towards the valuation of shares of M/s. Luxerati Retail Pvt. Ltd. 58. With regard to deletion of addition of INR 1,16,90,723/- made on unaccounted cash payment for construction of property, the AO in para 17.1 of the order observed that the search was also carried out simultaneously at the business premises of ENN V ENN Designs Pvt. Ltd. at 2798/2798A, Sushant Lok Road, Block-C, Phase-I, Sector-43, Gurgaon, wherein certain soft data was found with respect to the construction, architectural and other design related work of various properties which includes the digital evidences of the construction of immovable Page | 29 properties belonged to the assessee company. AO based on such documents, alleged that there were cash payments with respect to the construction of property situated at C-2604, Sushant Lok 1, Gurgaon which were not recorded in the books of accounts of the assessee and therefore, addition of INR 1,16,90,723/- was made being the difference of amount stated in Excel sheet and amount recorded in the books of accounts of the assessee company u/s 69A/115BBE of the Act which was deleted by ld. CIT(A). 59. Against this, Revenue is in appeal before the Tribunal. During the course of hearing Ld. CIT DR vehemently supported the order of the AO and submits that there were evidences were found as a result of search at the business premises of the company to whom entire civil construction/architectural /interior work was awarded by the assessee company for the property situated at t C-2604, Sushant Lok 1, Gurgaon. Ld. CIT DR further submits that the AO has relied upon the Excel Sheet found from the possession of Directors of the Contractor company wherein entries of payment in cash were found recorded. It is submitted by Ld. CIT DR that Ld. CIT(A) has deleted the addition by accepting the contention of the assessee that no payment whatsoever, was made during the year under appeal and the Excel Sheet do not contain any dates etc. Ld. CIT DR submits that the additions are based on the admission of one of the employee of Contractor as well as statement of the accountant of the assessee and therefore, requested for the restoration of the AO’s order. 60. On the other hand, Ld.AR for the assessee vehemently supported the order of Ld. CIT(A) and submits that Excel Sheet does not contain any date/mode of payment/particulars of the parties or the material for which alleged payments were made. It is further submitted by Ld.AR that the total work was awarded in INR 2 crores in terms of agreement dated 27.11.2018 and no payment whatsoever, was made during the year under appeal. He further submits that none of the paper contained any date and all the figure are in round figures which further suggests that they were mere estimations for which discussions were continued between the management of the assessee company and the contractor. Ld.AR submits that no additions on the basis of assumptions or presumption without any corroborative evidences could be made. He therefore, submits that Ld. CIT(A) has rightly deleted the additions which order deserves to be uphold. He prayed accordingly. 61. Heard the contentions of both the parties at length and perused the material available on record. It is observed that there was Page | 30 certain Excel Sheets found in digital data from the possession of the company Enn V ENN Designs Pvt. Ltd. who were awarded work for civil construction, architectural and interior design of the property owned by assessee situated at C-2604, Sushant Lok 1, Gurgaon. It is observed that the extract of Excel Sheet found from various digital data as reproduced in the assessment order at pages 196 to 208, all the figures noted therein are in round figures and at various stages. It is further observed that nowhere in the said documents, it is observed that any cash payments were made by the assessee to the contractor in addition to the amount which were recorded in the books of accounts. Ld. CIT DR appreciated these facts and deleted the additions made by AO by making following observing in para 8.1 to 8.9 of the order:-

Further, while deleting the additions in the present case, by allowing Ground of appeal No.3 in para 5.1 to 5.5 ld. CIT(A) has observed as under:-

Before us, the revenue has failed to controvert the finding of ld. CIT(A) that the figures noted in the Excel Sheets are estimations. Further no corroborative evidence was brought on record in support of the allegation that the assessee has made the cash payment as the burden is on the revenue to establish the cash payment as found noted in the unsigned Excel Sheets. The ld. CIT(A) also observed that many places in the Excel Sheet, is was stated “discuss” which clearly suggests that the figure noted are not final and subject to further discussion between the parties. If the AO has any doubts about the cost of construction declared by the assessee, he should refer the Page | 42 matter for valuation of cost of construction however, the AO has failed to take any action and merely on assumptions and presumptions concluded that the assessee has made the cash payment as found noted int eh Excel sheets.

In view of above discussion, we find no error in the order of ld. CIT(A) in deleting the addition and therefore, the order of ld. CIT(A) is upheld in this issue. Ground of appeal No. 3& 4 of the revenue are dismissed.

In the result, appeal of the Revenue is dismissed and appeal of the assessee is partly allowed.

Ground of appeal Nos. 1 to 3 raised by the assessee are against the initiation of reassessment proceedings u/s 147 of the Act. However, during the course of hearing no submission was made in support to these grounds of appeal therefore, the grounds of appeal No. 1 to 3 are dismissed.

Ground of appeal No.4 raised by the assessee is with respect to confirmation of addition of INR 33,50,000/- made u/s 69A r.w.s. 115BBE of the Act towards the on money received from the sale of property by holding the same as unexplained money.

Heard the contentions of both the parties at length and perused the material available on records. It is not in dispute that the assessee alongwith two other joint owners had received ‘on money’ of Rs. 67.00 lacs in cash in addition to the sale consideration declared in registered Sale Deed. Thus, the same cannot be deleted. However, it is observed that the AO made the addition u/s 69A for this on money by treating the same as unexplained money. Before going further, we first examine the provision of section 69A of the Act which reads as under:- Unexplained money, etc. 69A. “Where in any financial year the assessee is found to be the owner of any money, bullion, jewellery or other valuable article and such money, bullion, jewellery or valuable article is not recorded in the books of account, if any, maintained by him for any source of income, and the assessee offers no explanation about the nature and source of acquisition of the money, bullion, jewellery or other valuable article, or the explanation offered by him is not, in the opinion of the Assessing Officer, satisfactory, the money and the value of the bullion, jewellery or other valuable article may be deemed to be the income of the assessee for such financial year.”

The provisions of section 69A are applicable in cases where the assessee is found to be the owner of any money, bullion, jewellery and other valuable article and same is not recorded in any books of accounts and the sources of such sum is not explained to the satisfaction of the AO. Thus, for making addition u/s 69A of the Act, following conditions should be satisfied:

Section 69A of the Act is a deeming section and it is applicable only when all the aforesaid conditions are cumulatively found to exist. One of the important conditions to trigger the applicability of section 69A of the Act is that the assessee is found to be the owner of money, bullion, etc. or other valuable article in the financial year. The initial burden is on the Assessing Officer to establish that the assessee is the owner of the unexplained asset. This must be based on facts and evidence, not mere suspicion or presumption. Once ownership and non-recording are established, the burden shifts to the assessee to provide a satisfactory explanation for the asset's source. If the explanation is reasonable and supported by evidence, no addition should be made.

In the instant case, as observed above, there is no dispute that the said amount was received as a part of sale consideration and the identity of the seller is also disclosed thus it cannot be said that the source of this sum is not explained, rather the AO himself has observed that assessee has received this cash from the buyer thus the source is duly accepted by the AO. Once the source is established, provision of section 69A cannot be invoked for making addition of sale consideration received over and above the declared sale consideration in cash.

It is further observed that assessee has declared LTCG from the sale of his 50% share in the said property. However, the sale consideration is taken at Rs. 50.00 lacs only (50% of Rs. 1.00 cr) and 33,50,000/- being 50% of on money of INR 67 Lakhs remained excluded while computing income from Capital gains. Since the on money of INR 67.00 lacs was jointly received by the assessee alongwith other two co-owners at the time of sale of immovable property owned by them, it partakes the character of sale consideration and thus, the same cannot be held as unexplained money as the source of the same is explained as from the buyer of the property whose whereabouts are mentioned in the sale deed. Therefore, the on money so received should to be treated part of the sale consideration and should be taxed as ‘Income from capital gain’

Ground of appeal No.5 of the assessee is regarding the validity of the approval granted u/s 148B of the Act. Before us, no effective arguments were made by the ld. AR of the assessee, therefore, this ground of appeal is hereby dismissed.

In the result, appeal of the assessee is partly allowed.

Brief facts of the case are that the assessee has e-filed his return of income, declaring total income of INR 39,50,020/- on 20.12.2023. The assessment was completed u/s 143(3) by making various additions on account of unexplained gifts of INR 1,28,61,452/- as undisclosed cash receipts from sale of property of INR 36,66,666/-, Page | 47 undisclosed cash received from sale of property of INR 61,50,000/-, unexplained jewellery of INR 1,09,26,387/-, cash found during the course of search of INR 17 Lakhs u/s 69A of the Act and INR 8,16,000/- u/s 69B towards unexplained investment in luxury watch found during the course of search in possession of the assessee.

Against the said order, assessee preferred appeal before Ld. CIT(A) who vide order dated 13.08.2025 has deleted the additions of INR 89,81,452/- made on account of gifts received from father-in-law out of total addition of INR 1,28,61,452/- and confirmed the addition of INR 38,80,000/-. The addition made on account of own money received on sale of property from undisclosed receipt u/s 69A of the Act was confirmed. The addition made on account of investment in jewellery of INR 1,09,26,387/- u/s 69B was reduced to INR 25,97,479/-. The additions made u/s 69A on account of cash found during the course of search of INR 17 Lakhs is confirmed and addition of INR 8,16,000/- made towards the watch found during the course of search made u/s 69B was deleted by Ld. CIT(A).

Aggrieved by the order of Ld. CIT(A), both the parties are in appeal before the Tribunal.

Ground of appeal No.1 raised by the assessee is general in nature, needs no separate adjudication.

Ground of appeal No.2 raised by the assessee is with respect to the confirmation of addition of INR 38,80,000/- made u/s 69A/115BBE of the Act on account of gifts received by father-in-law as unexplained money. The revenue in Ground of appeal Nos. 1 & 2 has challenged the deletion of addition made on account of gifts u/s 69A of the Act of INR 89,81,452/- out of total addition of INR 1,28,61,452/- made by AO.

Before us, during the course of hearing, both the parties have fairly admitted that facts involved in this issue are identical to the facts in assessee’s own case for AY 2019-20 where the addition of identical nature were made towards the gifts received from father-in- law by holding the same as unexplained money u/s 69A of the Act.

While deciding the appeal of the assessee in ITA No. 5651/Del/2025 for Assessment Year 2019-20, we have already deleted the addition confirmed by ld. CIT(A) and further confirmed the order of ld. CIT(A) to the extent addition was deleted. Therefore, by following the observations made in ITA No.5651//Del/2025 for AY 2019-20 in assessee’s own case, which is Mutatis Mutandis applicable to the facts of the present case, Ground of appeal No.2 raised by the assessee is allowed and Grounds of appeal No. 1 & 2 of the revenue are dismissed.

Ground of appeal No.3 raised by the assessee is with respect to the addition made u/s 69A r.w.s. 115BBE of the Act towards on Page | 49 money received from sale of property of INR 36,66,666/- and Ground of appeal No.4 is regarding on unexplained money of INR 61,50,000/- received by the assessee from the sale of property.

Before us, both the parties have agreed that the issue in hand is identical with the issue in ITA No.5652/Del/2025 for Assessment Year 2021-22 where under identical circumstances, the on moony received by the assessee was treated as unexplained money u/s 69A of the Act by the AO. While deciding the aforesaid appeal of the assessee in ITA No.5652/Del/2025, we have held that the on money received by the assessee should be treated sale consideration and should be taxed under the head “Income from capital gain” and not u/s 69A of the Act. Since facts are same, thus, by following the aforesaid observations in ITA No.5652/Del/2025 which are Mutatis Mutandis applicable to the facts of present case also, we direct the AO to recompute the income from Capital gains by including the on money of 36,66,666/- and of Rs. 61,50,000/- in the total value of sales consideration and charge tax as per the rates prescribed under the Act. The, Grounds of appeal No. 3 & 4 raised by the assessee are thus partly allowed.

Ground of appeal No.5 of the assessee is with respect to the confirmation of the addition of INR 25,97,479/- out of the total addition of Rs. 1,09,23,687/- made u/s 69B on account of unexplained investment in jewellery found during the course of search. Whereas the revenue in Ground of appeal No.3 challenged the deletion of addition of INR 83,28,912/-.

Heard the contentions of both the parties at length and perused the material on record. During the course of search, at the residence of the assessee and lockers owned by the assessee jointly with his wife Smt. Simran Taneja, total jewellery worth INR 94,67,637/- and bullion of INR 14,58,750/- was found and seized. Thus, total unexplained income of INR 1,09,23,687/- were found and seized. During the course of assessment proceedings, the assessee was asked to file the necessary evidences for acquiring such jewellery however, the same was not provided and therefore, the AO has made the addition of the said sum u/s 69B r.w.s. 115BBE of the Act.

In first appeal, Ld. CIT(A) has deleted the addition to the extent of INR 83,28,912/- by holding that the said jewellery as received by assessee and his wife from his in-laws from time to time for which necessary copies of bills was also submitted. Ld. CIT(A) after considering the same and further by placing reliance on the judgement of Hon’ble Delhi High Court in the case of Ashok Chaddha vs. ITO [2011] 14 taxmann.com 57 (Del) and the decision of Co-ordinate Bench of Tribunal in the case of Vibhu Agarwal [2018] 93 taxmann.com 275 has held that looking to the social and family status of the assessee, receipt of jewellery as gifts on various occasions from the relatives cannot be doubted and the jewellery found in excess of CBDT Instruction No.1994 dated 11.05.1994 was Page | 51 held as acquired out of unexplained sources and addition of INR 25,97,479/- was confirmed and deleted the remaining addition of INR 83,28,912/-.

Before us, the Revenue has failed to controvert the findings of Ld. CIT(A) by placing any contrary material. Such findings of ld. CIT(A) are based on the judgements of Hon’ble Jurisdictional High Court and also as per the CBDT instruction No. 1914 dt.11.05.1994 therefore, we find no error in the order of Ld. CIT(A) in deleting the additions made to the extent of INR 83,28,912/- .

Regarding the remaining addition as sustained by ld. CIT(A) at INR 25,97,479/-, it is observed that assessee has failed to submit any evidence/material in support of acquisition of said jewellery therefore, the addition to this extent is hereby, upheld.

In the alternative, ld. AR for the assessee requested that the benefit of the telescoping and set off of the on money received in preceding and also in the year under appeal be given in the acquisition of jewellery held as unexplained. Ld. AR further claimed that application of on money received in cash elsewhere has not been found as a result of search nor claimed by the assessee. After considering the submission, we find force in the alternate argument of the ld. AR. Accordingly we direct the AO to allow the benefit of telescoping and setoff of the additions confirmed by us on account of on money received from the sale of properties as the application of Page | 52 said on money elsewhere has not been claimed by the assessee nor by the AO. With these directions, Ground of appeal No 5 of the assessee is partly allowed and Ground of appeal No. 3 raised by the Revenue is dismissed.

Ground of appeal No.6 raised by the assessee is with respect to the confirmation of addition of INR 17 Lakhs made on account of cash found during the course of search.

Heard the contentions of both the parties at length and perused the material on record. The assessee since beginning of the proceedings claimed that out of 17 Lakhs cash found from his residential premises at C-27, Sushant Lok, Phase-1, Gurugram, a sum of INR 09 Lakhs pertained to him which were accumulated out of the income received since past long and the remaining amount of INR 8 Lakhs belong to his father-in-law. However, no evidence could be filed in support of such claim therefore the addition was made by AO and sustained by Ld. CIT(A). Before us also, the assessee except reiterating the same arguments has failed to submit any evidence in support of the source of the cash so found.

In view of these facts and overall discussion made herein above, we find no error in the order of Ld. CIT(A) in confirming the addition made. However, ld. AR made an alternate claim that the benefit of telescoping and set off out of the additions confirmed on account of on money received in cash from the sale of property should be given. Page | 53 On careful consideration of the claim of the assessee, it is observed that the application of the on money so received from the sale of property in the year under appeal of INR 36,66,666/- & INR 61,50,000/- and also of INR 33.50 lacs in AY 2021-22 has not been applied elsewhere. While deciding the ground of appeal No. 5 of the assessee herein above, we have allowed the benefit of telescoping and set off of INR 25,97,479/- towards unexplained investment in jewellery. Likewise we further allow the benefit of telescoping towards cash of INR 17 Lakhs found during the course of search. The ground of appeal No. 6 of the assessee is thus partly allowed.

Ground of appeal No.7 of the assessee is regarding the validity of the approval granted u/s 148B of the Act. Before us, no effective arguments were made by the ld. AR of the assessee, therefore, this ground of appeal is hereby dismissed.

Ground of appeal No.4 of the Revenue is with respect to the deletion of addition of INR 8,16,000/- made u/s 69B on account of watch found during the course of the search on assessee.

Heard the contentions of both the parties at length and perused the material on record. The assessee since beginning of the proceedings claimed with said watch belonged to one of the customers of M/s Kapoor Watch Company namely, Shri Jatin Gandtora and submits his PAN & Aadhar alongwith complete address of the buyer. The assessee also filed the copy of the invoice through Page | 54 which the said watch was purchased by the buyer. It was the claim of the assessee that this watch was handed over to the assessee by the buyer for servicing and polishing and for this purpose, the same available with the assessee at the time of search.

Ld. CIT(A) appreciated these facts and deleted the addition made. Before us, Revenue has failed to controvert the findings given by Ld. CIT(A) who has accepted the claim of the assessee. It is further observed that despite of providing complete details of the real owner of the watch, no efforts were made by the AO by making independent verification from the buyer to verify the genuineness and correctness of the claim of the assessee. Under these circumstances, we find no error in the order of Ld. CIT(A) who has rightly deleted the additions made. Accordingly, Ground of appeal No.4 raised by the Revenue is dismissed.

Ground of appeal No.5 raised by the Revenue is general in nature hence, not adjudicated.

In the result, appeal of the assessee is partly allowed and appeal of the Revenue is dismissed.

In the final result, all appeals of the assessee in ITA Nos. 5651 to 5653/Del/2025 for Assessment Years 2019-20, 2021-22 & 2023-24 respectively, are partly allowed and both appeals of the Revenue in ITA Nos. 8028 & 8002/Del/2025 for Assessment Years 2019-20 & 2023-24 respectively, are dismissed.