ANIL DALMIA,JAIPUR vs. DCIT, CENTRAL CIRCLE-4, JAIPUR, JAIPUR

per provisions of law and lacks jurisdiction. The addition made by A.O. on the basis of reasons for reopening has been deleted in appeal. The very foundation of the reopening is non-existent. Further Notice u/s 148(A), being less than 7 days is illegal. The issue of notice u/s 148 and consequent reassessment proceedings deserves to be quashed.

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unexplained sources and addition of Rs. 3,71,550/- on account unexplained interest received by the assessee. 3. Assessee carried the matter before the Ld. CIT(A) by way of filing appeal who has partly allowed the same. Feeling aggrieved with the impugned order passed by the Ld. CIT(A), assessee has come up before the Tribunal by way of filing the present appeal. 4. We have heard Ld. ARs for the assessee and Ld. DR for the Revenue and perused the record available on file. 5. Undisputedly, in the first appellate proceedings, Ld. CIT(A) has partly allowed the appeal deleting the addition made by the Assessing Officer to the tune of Rs. 3,71,550/-, however confirmed the addition of Rs. 4,00,000/- u/s 69C of the Act. 6. Ld. AR for the assessee challenging the impugned addition of Rs. 4,00,000/- contended that the Assessing Officer has assumed jurisdiction on this issue on incorrect facts, because assessee has categorically shown, every details in the computation available at page 12 of the of the paper book and the assessee has also shown TDS details available at page 13 of the paper book. 7. Admittedly, addition of Rs. 4,00,000/- u/s 69C of the Act has been made by the Assessing Officer at the feg end of the assessment

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proceedings. Undisputedly, amount of Rs. 4,00,000/- added u/s 69C of the Act was not subject matter of the notice u/s 148 of the Act. 8. Perusal of the notice available at page 1 and 2 of the paper book shows that only interest income of Rs. 3,71,550/- was shown to have escaped assessment within the meaning of section 147 of the Act rather the same has been made, subject matter by the assessment vide show cause notice dated 26.03.2023. 9. Assessing Officer proceeded to make this addition on the basis of code name used by Shri Radha Mohan Maheshwari for the assessee as “Paper Ka Kaam” and further connected this information with the mobile Number of the assessee available in the contact details of Shri Radha Mohan Maheshwari. We failed to understand as to how the code name as “Paper Ka Kaam” and assessee’s mobile number in the contact list of Shri Radha Mohan Maheshwari can lead to the conclusion that assessee had paid interest/commission of Rs. 4,00,000/- from unexplained sources. To our mind the impugned addition of Rs. 4,00,000/- has been made on the basis of mere probabilities and self devised methodology having no legal basis. 10. In view of the matter addition of Rs. 4,00,000/- made by the Assessing Officer and confirmed by Ld. CIT(A) on account of

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interest/commission paid from unexplained sources, is not sustainable in the eye of law, hence order to be deleted. 11. Resultantly, the appeal filed by the assessee is hereby allowed. Order pronounced in the open court on 25-08-2026

Sd/- Sd/- (ANNAPURNA GUPTA) (KULDIP SINGH) ACCOUNTANT MEMBER JUDICIAL MEMBER Jaipur Dated:- 25/08/2026. *Santosh. Copy of the order forwarded to: 1. The Appellant- 2. The Respondent- 3. CIT 4. CIT(A) 5. DR, ITAT, Jaipur. 6. Guard File By order,

Asst. Registrar