GAUTAM CHOPRA,NEW DELHI vs. DCIT, JHANDEWALLAN EXTENSION

ITA 2567/DEL/2025Status: DisposedITAT Delhi21 January 2026AY 2021-202216 pages
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What did the Tribunal hold?

The Tribunal held that the Assessing Officer's satisfaction note for initiating re-assessment proceedings did not explicitly state that the seized material had a "bearing on the determination of the total income of such other person." This rendered the re-opening unsustainable.

What were the facts?

A search operation on M/s Design Workshop (India) revealed incriminating documents showing out-of-books cash sales. The assessee, Gautam Chopra, was identified as a client who made substantial cash payments for furniture purchases. Re-assessment proceedings were initiated against the assessee.

What were the issues?

Whether the re-assessment proceedings were validly initiated without the Assessing Officer recording satisfaction that the seized material had a bearing on the assessee's total income. Whether the addition on account of cash expenditure was justified.

Which sections of the Income-tax Act were involved?

Section 147,Section 148,Section 151,Section 69C

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Income Tax Appellate Tribunal, DELHI BENCH ‘B’, NEW DELHI

Before: SHRI ANUBHAV SHARMA & SHRI MANISH AGARWAL

For Appellant: Shri R.S. Singhvi, CA &
For Respondent: Shri Satyajeet Goel, Adv
Hearing: 13.01.2026Pronounced: 21.01.2026

PER MANISH AGARWAL, AM : The present appeal is filed by the assessee against the order dated 27.03.2025 of Ld. Commissioner of Income Tax (A)-27, New Delhi [“Ld. CIT(A)”] in Appeal No. CIT(A), Delhi-27/10058/2020- 21 passed u/s 250 of the Income Tax Act, 1961 [“the Act”] arising out of assessment order dated 08.03.2024 passed u/s 147 r.w.s. 143(3) of the Act pertaining to Assessment Year 2021-22. 2. Brief facts of the case are that a search & seizure operation u/s 132 of the Income Tax Act, 1961 (hereinafter referred as "the Act") was conducted on M/s Design W

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