ALOK & CO LLP,DELHI vs. DCIT,CENTRAL CIRCLE-28, DELHI

ITA 2735/DEL/2025Status: DisposedITAT Delhi11 March 2026AY 2016-17Bench: SHRI S. RIFAUR RAHMAN (Accountant Member), SHRI VIMAL KUMAR (Judicial Member)8 pages
AI SummaryPartly Allowed

What did the Tribunal hold?

The Tribunal held that the initiation of proceedings under Section 153C was not proper and bad in law as the additions made by the AO were not based on the satisfaction note. The Tribunal found no clear link between the bank withdrawals noted and the alleged accommodation entries, deeming the presumption made by the AO unsustainable.

What were the facts?

The assessee filed appeals against the orders of the CIT(A) for AY 2016-17 & 2017-18. The appeals stem from assessment orders passed under Section 153C of the Income Tax Act, which the assessee claims are fundamentally flawed, lacking jurisdiction, and barred by limitation.

What were the issues?

Whether the assessment proceedings initiated under Section 153C were valid without proper satisfaction and incriminating material, and whether additions made by the AO were beyond the scope of the satisfaction note.

Which sections of the Income-tax Act were involved?

Section 153C,Section 153D,Section 69A,Section 271(1)(c),Section 65B

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, DELHI BENCH ‘F’: NEW DELHI

Before: SHRI S. RIFAUR RAHMAN & SHRI VIMAL KUMAR

For Appellant: Shri Sumit Lal Chandani, Shri Shivam, Ms. Ananya Kapoor, Ms. Sejal
For Respondent: Ms. Monika Singh, CIT-DR
Hearing: 28/01/2026Pronounced: 11/03/2026

PER S. PRIFAUR RAHMAN, AM The assessee has filed appeals against the order of the Learned Commissioner of Income-Tax(Appeals)-25, New Delhi [“Ld. CIT(A)”, for short] dated 28.02.2025 for the Assessment Year 2016-17 & 2017-18. ITA No. 2735 & 2736/Del/2025

2.

Both the appeals are interconnected having common issues. Both the appeals are heard together and disposed off by this common order. We take the lead appeal as ITA NO. 2735/Del/ 2025 (AY 2016-17)

3.

The assessee has raised following grounds of appeal:

“1. That the notice

The order continues below.

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