JAGMOHAN SINGH BEDI,DELHI vs. INCOME TAX OFFICER, WARD 70(1), DELHI

ITA 5068/DEL/2024Status: DisposedITAT Delhi28 January 2026AY 2016-17Bench: SHRI C.N. PRASAD (Judicial Member), SHRI M. BALAGANESH (Accountant Member)1 pages
AI SummaryRemanded

What did the Tribunal hold?

The Tribunal observed that the addition was made substantively for AY 2017-18 and protectively for other years, leading to potential double taxation. The assessee argued he was merely an employee and not involved in IFAMA's financial activities.

What were the facts?

The assessee, an employee of Earth Infrastructure Limited, was appointed as a manager in a group company, IFAMA Builders & Developers Private Limited, on record only. The Assessing Officer (AO) made an addition of Rs. 59.18 crore under Section 69A, treating amounts received by IFAMA as unexplained money in the hands of the assessee.

What were the issues?

Whether amounts received by a company, where the assessee was a director on record but not actively involved, can be treated as unexplained money in the hands of the assessee under Section 69A. The validity of assessment proceedings initiated under Section 147/148 was also questioned.

Which sections of the Income-tax Act were involved?

Section 69A,Section 147,Section 148

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

Before: SHRI C.N. PRASAD & SHRI M. BALAGANESH

Hearing: 13.01.2026Pronounced: 28.01.2026

PER C.N. PRASAD, JM, These appeals are filed by the assessee against different orders of the Ld.Commissioner of Income Tax (Appeals) dated 31.08.2024 for the A.Y’s 2015-16 to 2018-19. 2. The assessee has raised following grounds of its appeal :- “1. That on the facts, circumstances and legal position of the case, the Worthy CIT(A), NFAC in Appeal No. NFAC/2014-15/10288583 has erred in passing order dtd. 30.05.2023 in contravention of provisions of S. 250

of the Income Tax Act, 1961 (hereinafter referred to as "Act").

2.

That on facts, circumstances and legal position of the case, Worthy CIT(A) has erred in confirming the actions of Ld. AO in initiating, continuing and then concluding

The order continues below.

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