RANJIT KUMAR YADAV,WEST VINOD NAGAR, DELHI vs. CIT (A) - 29, DELHI, JHANDEWALAN EXTENSION, DELHI

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ITA 8950/DEL/2025Status: DisposedITAT Delhi07 October 2026AY 2021-225 pages
AI SummaryRemanded

What did the Tribunal hold?

The Tribunal considered the findings of the authorities below and the arguments presented. It found that the additional evidences filed by the assessee under Rule 46A before the Ld. CIT(A) were essentially required to prove the assessee's points. Consequently, the Tribunal accepted the additional evidences and remanded the case back to the file of the Ld. CIT(A). The Ld. CIT(A) was directed to adjudicate the case after giving the assessee due opportunity as required under law. The assessee was also directed to file all documents and details before the Ld. CIT(A) as it deemed fit to prove its case in time. The Tribunal noted that the appeal was allowed for statistical purposes.

What were the facts?

The assessee, Ranjit Kumar Yadav, filed an appeal against the order dated 07.11.2025 passed by the Ld. CIT(A)-29, Delhi, for the assessment year 2021-22. The assessee contended that the CIT(A) erred by confirming assessment orders without considering additional clarifications and supporting documents, violating principles of natural justice. Specific grounds of appeal relate to additions made under Sections 69A, 69B, 69, and 68 of the Income Tax Act, 1961. The assessee also challenged the rejection of additional evidence under Rule 46A and the confirmation of interest and penalty proceedings. The assessee argued that the CIT(A) did not accept necessary additional evidence filed under Rule 46A, despite sufficient cause shown, which amounted to a denial of natural justice.

What were the issues?

1. Whether the CIT(A) erred in confirming the assessment order without considering additional clarifications and supporting documents, thereby violating principles of natural justice, as argued by the assessee? 2. Whether the CIT(A) erred in upholding additions under Section 69A based solely on WhatsApp chats without corroborative evidence and a Section 65B certificate, ignoring the assessee's role as a professional CA, as argued by the assessee? 3. Whether the CIT(A) erred in confirming additions under Section 69B based on an Excel sheet seized from a pen drive, which the assessee claimed was an internal estimate, and ignoring the registered sale deed and banking channels, as argued by the assessee? 4. Whether the CIT(A) erred in treating a personal advance under Section 69 as unexplained money, despite confirmation from the recipient and lack of interest, as argued by the assessee? 5. Whether the CIT(A) erred in confirming additions under Section 68 despite the submission of bank statements, loan confirmation, and PAN details of the lender, as argued by the assessee? 6. Whether the CIT(A) erred in rejecting additional evidence filed under Rule 46A during appellate proceedings, as argued by the assessee? 7. Whether the CIT(A) erred in confirming interest under Sections 234A, 234B, and 234C and penalty proceedings under Sections 271AAC and 270A, as argued by the assessee? The Revenue relied on the orders of the authorities below.

Which sections of the Income-tax Act were involved?

Section 69A,Section 69B,Section 69,Section 68,Section 234A,Section 234B,Section 234C,Section 271AAC,Section 270A,Section 65B

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, DELHI BENCH ‘H’, NEW DELHI

Before: MS. MADHUMITA ROY & SH. KRINWANT SAHAY

For Appellant: CA Sh. Pritam Kumar, Advocate
Hearing: 27/07/2026Pronounced: 07/10/2026

IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH ‘H’, NEW DELHI

BEFORE MS. MADHUMITA ROY, JUDICIAL MEMBER & SH. KRINWANT SAHAY, ACCOUNTANT MEMBER

ITA No.8950/Del/2025 Assessment Year: 2021-22 Ranjit Kumar Yadav Vs. CIT (A)-29 E-136/3, Block –E, West Jhandewalan Extension, Vinod Nagar, Delhi -110092 Delhi PAN NO.ACXPY5782A (APPELLANT) (RESPONDENT)

Appellant by Sh. Neeraj Mangla, CA Sh. Pritam Kumar, Advocate Respondent by Sh. Bhopal Singh, CIT DR

Date of hearing: 27/07/2026 Date of Pronouncement: 07/10/2026

ORDER PER KRINWANT SAHAY, AM Appeal in this case has been filed by the assessee against the order dated 07.11.2025 passed by the Ld. CIT(A)-29, Delhi for the 2021-22. Grounds of appeal are as under :-

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1.

On Natural Justice and Procedure The CIT A erred in confirming the assessment order passed without considering the additional clarifications with supporting documents which is in violation of principles of natural justice. On Addition under Section 69A 1859480 The CIT A erred in upholding the addition based solely on WhatsApp chats without any corroborative evidence linking the transactions to the Appellants bank accounts. The CIT A ignored that the Appellant was acting as a professional CA facilitating client transactions and not for his personal benefit. The CIT A failed to appreciate that digital evidence without a certificate under Section 65B 4 of the Indian Evidence Act, 1872, is inadmissible. Rs. 580158 2. On Addition under Section 69B 1100000 The CIT A erred in confirming the addition based on an Excel sheet seized from the Appellants pen drive, which was merely an internal estimate and not a record of actual payment. The registered sale deed clearly reflects the consideration as 18000000, supported by banking channels and TDS compliance. The CIT A overlooked that the Excel sheet is inadmissible as evidence in the absence of a Section 65B4 certificate.

3.

On Addition under Section 69 1933093 The CIT A erred in treating a personal advance to Shri Kaushlendra Jha from tax paid savings as unexplained money. The CIT A ignored the confirmation from the recipient and the fact that no interest was charged OR received. The burden to prove the source was discharged, and the Revenue failed to rebut the same. Rs. 603125

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4.

On Addition under Section 68 18600000 The CIT A erred in confirming the addition despite submission of bank statements, loan confirmation, and PAN details of the lender, Ms. Manoj Kate. The CIT A failed to appreciate that the loans were genuine, received through banking channels, and were supported by declarations and creditworthiness evidence. On Admission of Additional Evidence under Rule 46A The CIT A erred in rejecting additional evidence filed during appellate proceedings despite sufficient cause shown and denial of opportunity during assessment. On Interest under Sections 234A, 5 234B, and 234C. The CIT A erred in confirming interest without proper computation and without considering the adjusted income. On Penalty Proceedings The CIT A erred in not dropping penalty proceedings under Sections 271AAC and 270A, which do not survive if the additions are deleted. Rs.16283927

2.

During proceedings before us the Ld. Counsel of the assessee argued that the Ld. CIT(A) did not accept the additional evidences filed by the assessee which are necessary for explaining the various transactions conducted by the assessee. The Ld. Counsel also argued that the denial of admission of additional evidences under Rule 46A by the Ld. CIT(A) was despite sufficient cause shown for not filing of such evidences during assessment proceedings and accordingly it was argued by the Ld. Counsel of the assessee that it is in a way denial of natural justice to the assessee.

3.

Per contra the Ld. DR relied on the orders of the authorities below. 3 | P a g e

4.

We have considered the findings given by the authorities below and we have also considered the arguments made by both the parties during proceedings before us. We find that the additional evidences filed by the assessee under Rule 46A before the ld. CIT(A) are essentially required to prove point of the assessee, therefore, we accept the additional evidences filed by the assessee and the case is remanded back to the file of the Ld. CIT(A) to adjudicate the case after giving due opportunity to the assessee as required under law.

5.

The assessee is also directed to file all the documents and details before the Ld. CIT(A) as it deems fit to prove its point in time.

6.

In the result, the appeal filed by the assessee is allowed for statistical purpose.

Order pronounced in the court on 07.10.2026.

Sd/- Sd/-

[MADHUMITA ROY] [KRINWANT SAHAY] JUDICIAL MEMBER ACCOUNTANT MEMBER Dated:07.10.2026 Neha, Sr. PS

4 | P a g e SHASHI Digitally signed by SHASHI KANT KANT PANDEY Date: 2026.10.09 PANDEY 15:25:39 +05'30'

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