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Facts
The assessee's appeal for AY 2017-18 arises against the order of CIT(A) involving proceedings under section 143(3) of the Income-tax Act, 1961. A delay of four days in filing the appeal was condoned. The appeal challenges additions made by the lower authorities.
Held
The tribunal held that the sum of Rs.80,833 was properly accounted for by the assessee with banking channel details. Regarding the addition of Rs.1,86,148 under section 115BBC, it was found that the assessee had provided all relevant details of contributors/donors and bank details, which were not controverted.
Key Issues
Whether the additions made by the lower authorities regarding sums of Rs.80,833 and Rs.1,86,148 are justified, considering the assessee's explanation and submitted details.
Sections Cited
143(3), 115BBC, 115BBC(1)(i)(A)
AI-generated summary — verify with the full judgment below
Income Tax Appellate Tribunal, DELHI BENCH: “SMC” NEW DELHI
Before: SHRI SATBEER SINGH GODARA
Date of hearing 21.01.2026 Date of pronouncement 21.01.2026 ORDER This assessee’s appeal for assessment year 2017-18, arises against the Commissioner of Income Tax (Appeals)/Addl./JCIT (A)- 5, Kolkata’s order dated 17.10.2025 having DIN and order no. ITBA/APL/S/250/2025-26/1081865660(1), involving proceedings under section 143(3) of the Income-tax Act, 1961 (hereinafter referred to as ‘the Act’). Heard both the parties. Case file perused.
Delay of four days in filing the asseessee’s instant appeal is condoned in larger interest of justice and in light of Collector, Land & Acquisition vs. Mst. Katiji & Others (1987) 167 ITR 471 (SC).
Coming to the assessee’s former substantive grounds challenging both the learned lower authorities’ respective findings adding the sum in question of Rs.80,833/- for the sole reason that the same had not been explained, learned counsel invites the tribunal’s attention to page 21 in the paper-book wherein it had already accounted for the very receipt received by banking channel along with the bank details.
The factual position regarding the latter issue of section 115BBC addition of Rs.1,86,148/- treated as anonymous in nature in both the lower proceedings; would hardly be any different as the assessee appears to have filed all the relevant details of its contributors/donors along with the bank details, which have nowhere been specifically controverted. That being the case, the tribunal finds no merit in both the learned lower authorities’ respective findings invoking section 115BBC(1)(i)(A) of the Act. Both the impugned additions are hereby deleted in preceding terms therefore.
This assessee’s appeal is allowed. Order pronounced in the open court on 21st January, 2026
2 | P a g e Sd/- (SATBEER SINGH GODARA) JUDICIAL MEMBER Dated: 10th February, 2026. RK/- Copy forwarded to: 1. Appellant 2. Respondent 3. CIT 4. CIT(A) 5. DR Asst. Registrar, ITAT, New Delhi
3 | P a g e