DEPUTY COMMISSIONER OF INCOME TAX, DELHI vs. RAVI BHARADWAJ, DELHI

ITA 2230/DEL/2025Status: DisposedITAT Delhi21 January 2026AY 2011-12Bench: SHRI S.RIFAUR RAHMAN (Accountant Member), SHRI ANUBHAV SHARMA (Judicial Member)1 pages
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What did the Tribunal hold?

The Tribunal held that the additions made by the AO were not sustainable as they were based on information from public domain and foreign tax jurisdiction, and not on material found during search and seizure operations. The Tribunal also noted that the protective assessment was made prior to substantive assessment under the Black Money Act, rendering it invalid. Therefore, the CIT(A) was justified in deleting the additions.

What were the facts?

The Revenue filed appeals against the order of the CIT(A) for Assessment Years 2011-12 to 2013-14. The appeals concerned additions made by the AO on the basis of information received from BVI authorities regarding undisclosed foreign bank accounts and assets offshore of the assessee, Ravi Bharadwaj, who was a director and shareholder of a BVI company, Lazare International Group Limited.

What were the issues?

Whether the additions made by the AO based on offshore information without incriminating material found during search were sustainable. Whether a protective assessment made prior to substantive assessment under the Black Money Act is valid.

Which sections of the Income-tax Act were involved?

Section 132,Section 153A,Section 143,Section 142(1),Section 68,Section 57,Section 10(3)

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Cases cited in this judgment(3)Show list

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Income Tax Appellate Tribunal, DELHI BENCHES ‘A’: NEW DELHI.

Before: SHRI S.RIFAUR RAHMAN & SHRI ANUBHAV SHARMA

For Appellant: Shri V.K. Agarwal, Advocate, Shri Hritik Lamba, Advocate
For Respondent: Shri Jitender Singh, CIT DR
Hearing: 04.11.2025

PER S. RIFAUR RAHMAN, ACCOUNTANT MEMBER :

1.

The Revenue has filed appeals against the order of the Learned Commissioner of Income Tax (Appeals), Delhi - 31 [“Ld. CIT (A)”, for short] dated 23.01.2025 for the Assessment Years 2011-12 to 2013-14. 2. Since the issues are common and the appeals are connected, hence the same are heard together and being disposed off by this common order. We take up the Revenue’s appeal being ITA No.2232/Del/2025 for Assessment Year 2013-14 as lead case to adjudicate the issues under consideration.

3.

Brief facts of the case are, in the case of the assessee, a search and seizure operation u/s 132 of the Income-tax Act 1961 (for short ‘the Act

The order continues below.

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