ABHI BUILDERS,GHAZIABAD vs. ACIT, NEW DELHI

IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH ‘SMC’, NEW DELHI Before Sh. Satbeer Singh Godara, Judicial Member : Asstt. Year : 2011-12 Deepak Mehta, Vs Income Tax Officer, 77-B, IFFCO Road, Sector-18, Ward-1(4), Gurgaon-122015 Gurgaon-122015 (APPELLANT) (RESPONDENT) PAN No. AMTPM1789P Assessee by: Sh. Deepak Mehta (Assessee) Revenue by : Sh. Manoj Kumar, Sr. DR Date of Hearing: 30.10.2025 Date of Pronouncement: 30.10.2025 ORDER

This assessee’s appeal for Assessment Year 2011-12, arises against the CIT(A)/NFAC, Delhi’s DIN & order No. ITBA/NFAC/S/250/2025-26/1079147594(1) dated 31.07.2025, in proceedings u/s 143(3) of the Income Tax Act, 1961 (in short “the Act”).

Ranjana Jatwani 4. It is in this factual backdrop that the assessee himself vehemently contents that he had very well explained the source of the impugned cash deposits as his parents and grand- parents past accumulated savings which has been wrongly rejected in both the lower proceedings. The Revenue could hardly dispute that keeping in mind the assessee’s and his family’s socio economic status wherein he is stated to be assessed at the maximum marginal rate all along, such past accumulated savings could not be altogether denied. The fact however remains that it was the assessee’s onus only to plead and prove the source of the impugned cash deposits by filing his cogent supportive evidence before both the learned lower authorities. Be that as it may, it is thus deemed appropriate in these peculiar facts that a lump sum addition of Rs.1,00,000/- only would be just and proper with a rider that the same shall not be treated as a precedent. The assessee gets relief of Rs.7,00,000/- in other words. Necessary computation shall follow as per law.