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Facts
The assessee filed an appeal for AY 2014-15 against an order passed under Section 147, challenging an addition of Rs. 24.50 lakh. This addition concerned a gold loan of Rs. 28,33,247/- which the assessee had given to her son and received back into her bank account, for which she provided supporting evidence.
Held
The Tribunal held that the assessee had duly explained the source of the impugned addition of Rs. 24.50 lakh with relevant evidence and bank statements. As the Revenue did not rebut this explanation, the addition was deleted. Other grounds of appeal were not pressed by the assessee's counsel.
Key Issues
Whether the addition of Rs. 24.50 lakh related to a gold loan transaction with the son was sustainable, given that the assessee provided explanation and evidence which remained unrebutted by the Revenue.
Sections Cited
Income Tax Act, 1961: Section 147
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Income Tax Appellate Tribunal, DELHI BENCH ‘SMC’ NEW DELHI
Before: SHRI SATBEER SINGH GODARA
O R D E R PER SATBEER SINGH GODARA, JM:
This assessee’s appeal for assessment year 2014-15 arises against National Faceless Appeal Centre (NFAC), Delhi’s DIN and order no. ITBA/NFAC/S/250/2023-24/1059306363(1), dated 03.01.2024, in case no. NFAC/2013-14/10071790, in proceedings u/s 147 of the Income-tax Act, 1961, hereinafter referred to as the ‘Act’.
Heard both the parties. Case file perused.
Learned counsel representing the assessee only presses for an addition of Rs. 24.50 lakh representing gold loan of 28,33,247/- which had been given to the son and received back from his bank account only. The assessee has admittedly filed all the relevant evidence and bank statement to this effect which remain unrebutted from the Revenue’s side.
Faced with this situation, since source of impugned addition of Rs. 24.50 lacks has duly been explained at the behest of the assessee, the same stands deleted. All other remaining grounds are not pressed during the course of hearing.
This assessee’s appeal is partly allowed in above terms.
Order pronounced in open court on 16.12.2024.