What did the Tribunal hold?

The Tribunal held that the AO made the addition based on loose papers/WhatsApp messages without corroborative evidence. Since the assessee provided affidavits and Shri Bhagwan Lal owned up to the transaction, the addition was unjustified.

The Assessing Officer (AO) made an addition of Rs. 8,57,230/- on account of undisclosed transactions with M/s Zoha Enterprises. The assessee claimed the transaction belonged to Shri Bhagwan Lal and provided affidavits from herself, her son, and Shri Bhagwan Lal.

What were the issues?

Whether the addition made by the AO on the basis of uncorroborated evidence, despite the assessee providing supporting affidavits, was justified.

Parwati Devi Mittal, Beawer vs ITO | s.250 | ITAT Jaipur 2026

Income Tax Appellate Tribunal, JAIPUR BENCHES, “SMC” BENCH, JAIPUR

Before: SHRI SANJAY GARG

For Appellant: Adv &

Hearing: 23.03.2026Pronounced: 15.05.2026

P a g e | 1 ITA No.866/JPR/2025 Parwati Devi Mittal, Beawer IN THE INCOME TAX APPELLATE TRIBUNAL, JAIPUR BENCHES, “SMC” BENCH, JAIPUR BEFORE SHRI SANJAY GARG, JUDICIAL MEMBER ITA No.866/JPR/2025 (Assessment Year:2018-19) Parwati Devi Mittal Vs. Income Tax Officer, c/o Laxminarayan Ward 1 Agarwal, Beawer MaszidGaliTejaChowk, Beawar, Ajmer 305901 �थायीलेखासं./जीआइआरसं./PAN/GIR No:AJRPM6008N Appellant .. Respondent

Appellant by : Sh. Devang Gargieya, Adv & Sh. Mahendra Gargieya, Adv. Respondent by : Sh. Gaurav Awasthi, JCIT Date of Hearing 23.03.2026 Date of Pronouncement 15.05.2026 O R D E R

The present appeal has been preferred by assessee against the order of National Faceless Appeal Centre (NFAC)/Ld. Commissioner of Income Tax (Appeals) (hereinafter referred to as “Ld. CIT(A)”) dated 11.04.2025, passed u/s 250 of the Income Tax Act, 1961 (in short “the Act”).

The assessee in this appeal has contested the confirmation of addition made by the Assessing Officer (in short, “the AO”) of Rs.8,57,230/- on

P a g e | 2 ITA No.866/JPR/2025 Parwati Devi Mittal, Beawer account of some undisclosed transactions of the assessee with M/s Zoha Enterprises.

A search and seizure action was carried out on the premises of M/s Zoha Enterprises, during which certain documents were found. Name of the assessee was also appearing in the said documents relating to some of the transactions. On being asked to explain, the assessee reconciled most of the transactions; however, could not reconcile the transaction of expenditure of Rs.8,57,230/-. In that respect, the assessee submitted that the said transaction did not belong to the assessee, but to some Shri Bhagwan Lal. The assessee, in this respect, not only placed on file her own affidavit, her son Nitu’s affidavit but also the affidavit of said Shri Bhagwan Lal, who also owned up the said transaction which was taken into account in his return of income. However, the AO rejected all the contentions of the assessee and made the impugned addition observing that all the explanation was an afterthought. The Ld. CIT(A) confirmed the addition so made by the AO.

I have heard the rival contentions and gone through the record.The impugned addition has been made by the AO on the basis of some loose paper/WhatsApp message.There was no corroborative evidence found relating to the aforesaid transaction from which it can be concluded that the said transaction belonged to the assessee. The assessee owned up many transactions and furnished the necessary details and accordingly, reconciled the same also. Relating to this

P a g e | 3 ITA No.866/JPR/2025 Parwati Devi Mittal, Beawer particular transaction, the assessee not only filed her own affidavit but also the affidavit of Shri Bhagwan Lal who duly owned up the said transaction as belonging to him. There was no contrary evidence on the file for the AO to reject the contention of the assessee. Therefore, the AO was not justified for making the impugned addition; the same is accordingly ordered to be deleted.

In the result, appeal of the assessee stands allowed.

Order is pronounced under provision of Rule 34 of ITAT Rules, 1963 on 15/05/2026.

Sd/- (Sanjay Garg) Judicial Member Dated 15.05.2026 Mittali, Sr. PS Copy forwarded to: 1. Appellant 2. Respondent 3. CIT 4. CIT(Appeals) 5. DR: ITAT By Order,

Asst. Registrar ITAT, Jaipur

PARWATI DEVI MITTAL , BEAWER,BEAWER vs. ITO,WD-1, BEAWER, BEAWER

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