SONICA SACHDEVA TH THE LEGAL HEIR DEEPAK SACHDEVA,GHAZIABAD vs. ACIT, GHAZIABAD

ITA 5051/DEL/2025Status: DisposedITAT Delhi13 February 2026AY 2022-23Bench: SHRI MAHAVIR SINGH, HON'BLE (Vice President), SHRI S. RIFAUR RAHMAN, HON'BLE (Accountant Member)1 pages
AI SummaryPartly Allowed

What did the Tribunal hold?

The tribunal held that the AO and CIT(A) misunderstood the explanation regarding the FDR maturity proceeds, remitting the issue for verification. Regarding the share valuation, the tribunal found the AO exceeded jurisdiction and directed the addition to be deleted. For brokerage charges, the tribunal found no basis for restricting it to 0.5% and allowed the assessee's claim of 1%.

What were the facts?

The assessee appealed an order from the NFAC upholding the AO's addition of Rs. 6,20,000 as unexplained money from an unsecured loan. The assessee claimed the loan was out of their bank account, supported by FDR maturity proceeds. Another issue involved the CIT(A) sustaining an addition of Rs. 14,10,142 based on recalculating the fair market value of shares sold. Finally, the disallowance of brokerage charges of Rs. 3,85,002 was contested.

What were the issues?

Whether the additions made on account of unsecured loan, share valuation, and brokerage charges are justified.

Which sections of the Income-tax Act were involved?

Section 69A,Section 143(3),Section 11UA

AI-generated summary — verify with the full judgment below

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

Before: SHRI MAHAVIR SINGH, HON’BLE & SHRI S. RIFAUR RAHMAN, HON’BLE

For Appellant: Shri A.K. Khurana, CA
For Respondent: Ms. Ankush Kalra, Sr. DR
Hearing: 12.02.2026Pronounced: 12.02.2026

PER MAHAVIR SINGH, VICE PRESIDENT :

This appeal has been filed by the Assessee is arising out of the order of Ld. National Faceless Appeal Centre (NFAC), Delhi in Appeal No. NFAC/2021- 22/10345198 dated 26.6.2025. Assessment was framed by ACIT, Circle2(1)(1), Ghaziabad for the assessment year 2022-23 u/s. 143(3) of the Income Tax Act, 1961 (hereinafter referred the Act) vide order dated 31.3.2024. 2. The first issue in this appeal by the assessee is as regards to the order of the Ld. CIT(A) confirming the action of the AO for making addition on account of unsecured loan as unexplained money amounting to Rs. 6,20,000/- u/s. 69A of the Act.

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