ANISHA GUPTA,NOIDA vs. ACIT,CIRCLE-60(1), DELHI

ITA 6352/DEL/2025Status: DisposedITAT Delhi27 January 2026AY 2010-11Bench: SHRI MAHAVIR SINGH, HON'BLE (Vice President), SMT. RENU JAUHRI, HON'BLE (Accountant Member)1 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal directed the CIT(A) to consolidate the assessee's appeal with the appeal of Hydro Technology. Both appeals were to be decided together to determine where the substantive addition should be confirmed, particularly regarding a cash payment of Rs. 67,75,000/-.

What were the facts?

The assessee's appeal arose from an order of the NFAC and involved an addition made by the AO on a protective basis under Section 69C for unexplained expenditure. The AO had issued a notice under Section 148 for protective assessment, with substantive addition to be made in the case of Hydro Technology.

What were the issues?

Whether the substantive addition for unexplained expenditure should be made in the hands of the assessee or Hydro Technology, and whether the appeals should be consolidated for a joint decision.

Which sections of the Income-tax Act were involved?

Section 143(3),Section 147,Section 148,Section 69C

AI-generated summary — verify with the full judgment below

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

Before: SHRI MAHAVIR SINGH, HON’BLE & SMT. RENU JAUHRI, HON’BLE

For Appellant: Adv. & Ms. Uma Upadhyay, CA
Hearing: 20.01.2026Pronounced: 20.01.2026

PER MAHAVIR SINGH, VP:

This appeal by the assessee is emanating from the order of the NFAC, Delhi in appeal No. CIT(A), Delhi-19/10447/2017-18 dated 2.9.2025. Assessment was framed by the AO u/s. 143(3) r.w.s. 147 of the Income Tax Act, 1961 dated 20.12.2017 relating to assessment year 2010-11. 2. At the outset, Ld. Counsel for the assessee Shri Ved Jain pointed out that in assessee’s case the addition of unexplained expenditure u/s. 69C was made by the AO on protective basis. He took us through the assessment order wherein, this fact is recorded in para 7. Simultaneously, he took us through the reasons recorded, which are enclosed at Assessee’s Paper Book Page 81 and sta

The order continues below.

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