NITISH JAIN,DELHI vs. ITO, WARD 54(1), DELHI, DELHI

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ITA 7452/DEL/2025Status: DisposedITAT Delhi20 January 2026AY 2019-20Bench: IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH `SMC', NEW DELHI Before Sh. Satbeer Singh Godara, Judicial Member ITA No. 7452/Del/2025 : Asstt. Year: 2019-20 Nitish Jain, Vs Income Tax Officer, 41, Bhogal Road, Jangpura, Ward-54(1), Bhogal, New Delhi-110014 New Delhi-110002 (APPELLANT) (RESPONDENT) PAN No. AHFPJ0396Q Assessee by: Sh. Raman Kumar Goyal, AR Revenue by : Sh. Manoj Kumar, Sr. DR Date of Hearing: 20.01.2026 Date of Pronouncement: 20.01.2026 ORDER This assessee's appeal for Ass1 pages

In favour of the assessee: the assessee's appeal was allowed. From the AI summary of this appeal.

AI SummaryAllowed

What did the Tribunal hold?

The Tribunal noted that the excel sheet was a self-contained document and not in the nature of a payment or receipt. There was no corroboration of its contents by the lower authorities. Therefore, the addition made based on this excel sheet was found to be without merit.

What were the facts?

The assessee is aggrieved by an assessment order and the order of the CIT(A)/NFAC for AY 2019-20. The lower authorities held that the assessee invested Rs. 2,00,000/- with M/s Omaxe Ltd. for purchasing a unit, which was based on an excel sheet found during a search.

What were the issues?

Whether the addition of Rs. 2,00,000/- based on an uncorroborated excel sheet found during a search is justified.

Which sections of the Income-tax Act were involved?

Section 147

AI-generated summary — verify with the full judgment below

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

Before: Sh. Satbeer Singh Godara

Hearing: 20.01.2026Pronounced: 20.01.2026

ORDER This assessee’s appeal for Assessment Year 2019-20 arises against the CIT(A)/NFAC, Delhi’s DIN & order No. ITBA/NFAC/S/250/2025-26/1081417766(1) dated 03.10.2025, in proceedings u/s 147 of the Income Tax Act, 1961 (in short “the Act”).

2.

Heard both the parties at length. Case file perused.

3.

It transpires during the course of hearing that the assessee/appellant is aggrieved against both the learned lower authorities respective findings holding him to have invested on- money of Rs.2,00,000/- with builder/developer M/s Omaxe Ltd. whilst purchasing a unit No. HFFC/Shop-65 in the project named Hi Fun Food Court, Faridabad; in assessment order dated 20.12.2024 and upheld in the lower appellate discussion.

1.

Nitish Jain 4. Both the learned representatives vehemently reiterate their respective stands against and in support of the impugned addition. The Revenue more particularly seeks to buttress the point that the impugned addition has rightly been made in the assessee’s hands since based on an excel sheet found/seized during the course of search at M/s Omaxe Ltd. It could hardly dispute that the said alleged excel sheet is only a self- contained document which is not even in the nature of either payment or a receipt coming at the assessee’s behest. There is further no corroboration of the said excel sheet contents made by both the learned lower authorities. That being the case, no merit is found in the impugned addition of Rs.2,00,000/- which is hereby deleted in very terms.

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