RAMAN GOYAL,CHANDIGARH vs. DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE 1, CHANDIGARH

ITA 40/CHANDI/2025Status: DisposedITAT Chandigarh02 February 2026AY 2015-16Bench: SHRI RAJPAL YADAV (Vice President), SHRI MANOJ KUMAR AGGARWAL (Accountant Member)5 pages
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What did the Tribunal hold?

The Tribunal upheld its previous ruling, stating that an unsigned agreement, not acted upon or signed by the assessee, cannot be considered "incriminating material." The AO failed to provide other evidence to support a higher fair rental value for the property. Therefore, the addition made based solely on such a document was deemed invalid and ordered to be deleted.

What were the facts?

The assessee, Raman Goyal, held a 50% share in a property and declared Rs. 90,000 as rental income. Following a search, the AO discovered an unsigned agreement suggesting a higher annual rental value of Rs. 3 lakhs for the property, leading to an addition of Rs. 42,000/- for AYs 2015-16, 2018-19, and 2019-20. This addition was contested, referencing previous Tribunal decisions in the assessee's own case that had deleted similar additions for other assessment years.

What were the issues?

1. Whether an unsigned agreement constitutes "incriminating material" for making additions to income during search assessments. 2. Whether the addition to rental income based solely on an unsigned agreement, without further evidence, is legally tenable.

Which sections of the Income-tax Act were involved?

Section 23(1),Section 143(2),Section 143(3),Section 132(1),Section 153A

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Income Tax Appellate Tribunal, DIVISION BENCH, ‘B’ CHANDIGARH

Before: SHRI RAJPAL YADAV & SHRI MANOJ KUMAR AGGARWAL

For Appellant: Shri Yogesh Monga, CA
For Respondent: Shri Bharat Bhushan Garg, CIT DR
Hearing: 29.01.2026Pronounced: 02.02.2026

PER RAJPAL YADAV, VP

The present three appeals are directed at the instance of the assessee against the separate orders of even dated i.e.

ITA No.40, 35 & 36/CHD/2025 A.Y.2015-16, 2018-19,2019-20 2

08.11.

2024 passed for assessment year 2015-16, 2018-19 and 2019-20. 2. The assessee has taken 9 grounds of appeal in each assessment year, however, her grievance

The order continues below.

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