SH. PARAS KUMAR CHHABRA S/O. SH. RAM PARKASH,AMRITSAR vs. INCOME TAX OFFICER WARD-1(1), AMRITSAR

ITA 906/ASR/2025Status: DisposedITAT Amritsar29 September 2026AY 2022-235 pages
AI SummaryRemanded

What did the Tribunal hold?

The Tribunal held that the assessee had made detailed submissions with corroborative documentary evidence and reconciliation to explain the differences that led to the additions. However, these submissions were not considered or examined by the authorities below before arriving at adverse conclusions. The Tribunal found it appropriate to accept the assessee's prayer to remit the matter back to the Assessing Officer (AO) for de novo adjudication. The AO is directed to consider all the materials placed on record and adjudicate the matter afresh. The assessee will be given a reasonable opportunity of being heard and to make further submissions. The grounds taken by the assessee were allowed for statistical purposes. The operative direction is to set aside the orders of the authorities below and restore the matter to the AO for fresh consideration.

What were the facts?

The assessee, Paras Kumar Chhabra, a registered stamp vendor, is in appeal against the order of the CIT(A), NFAC, Delhi, dated 18.11.2025, which upheld the additions made by the AO under section 143(3) r.w.s. 144B on 15.03.2024 for Assessment Year 2022-23. The assessee's business involves collecting cash for stamp duty and registration fees, which are then deposited in bank accounts and paid to Stock Holding Corporation of India (SHCI) for e-stamping or to the Punjab Govt treasury. During the year, the assessee made cash deposits totaling Rs.9,06,63,420/-. The AO treated Rs.4,15,57,450/- as unexplained money under section 69A and Rs.2,75,57,521/- as unexplained credit under section 68, assessing total income at Rs.6,96,11,481/-. The CIT(A) dismissed the assessee's appeal.

What were the issues?

1. Whether the additions made by the Assessing Officer (AO) under section 69A and section 68 of the Income-tax Act, 1961, are justified, considering the assessee's submissions and documentary evidence? Assessee's contentions: - The assessee provided detailed submissions, corroborative documentary evidence, and reconciliation to explain the differences between declared income and bank transactions. - The CIT(A) did not provide an in-person hearing despite a request and did not call for a remand report or conduct verification from SHCI or the Punjab Government, despite the assessee furnishing login credentials for e-stamping and e-registration fee collection portals. - The authorities below failed to examine the materials placed on record and made additions solely based on discrepancies without considering the reconciliation. - The AO did not exercise powers available under section 133(6). - The assessee prayed for the matter to be restored to the AO for de novo adjudication after considering all materials. Revenue's contentions: - The learned DR relied on the orders of the authorities below.

Which sections of the Income-tax Act were involved?

Section 69A,Section 68,Section 143(3),Section 144B,Section 250,Section 133(6)

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, AMRITSAR BENCH, AMRITSAR.

Before: SH. SAKTIJIT DEY, HON’BLE & SH. GIRISH AGRAWAL, HON’BLE

Hearing: 28.09.2026Pronounced: 29.09.2026

PER GIRISH AGRAWAL, ACCOUNTANT MEMBER:

This appeal is filed by the assessee against the order of ld. CIT(A), NFAC, Delhi, passed u/s 250 of the Income-tax Act, 1961, (the Act) dated 18.11.2025, which has emanated from the order of the ld. AO, passed u/s 143(3) r.w.s. 144B of the Act, dated 15.03.2024. 2. Brief facts as culled out from the record are that assessee is a registered stamp vendor authorised by Govt of Punjab since 1997. Business of assessee involves collection of cash for stamp duty and registration fees from deed writers and property Paras Kumar Chhabra 2 Assessment Year: 2022-23 purchaser. T

The order continues below.

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