MEENAKSHI GUPTA,NEW DELHI vs. ITO,WARD-35(6), DELHI

Coming to assessee’s first and foremost substantive ground challenging validity of the impugned reopening for want of valid reasons recorded as well as due approval under section 151 of the Act, learned departmental representative has invited the undersigned’s attention to pages 17 and 18 of the paper-book that the Assessing Officer herein had strictly gone by the corresponding tangible material whilst setting into motion the section 148/147 proceedings. He next takes the undersigned to the prescribed authority’s approval at pages 19 to 20 indicating due application of mind as well. These assessee’s legal grounds are declined therefore. 4. The latter substantive issue between the parties i.e. correctness of the impugned addition of Rs.25 lakhs treated as unexplained/undisclosed income, of the assessee in the course of assessment framed on 23rd December, 2019, as upheld in the lower appellate discussion. 5. The Revenue has invited the tribunal’s attention to the case records which sufficiently prove that the assessee had got an amount of Rs.25 lakhs transferred in her bank account from one entity M/s. Oxygen Projects Ltd. which was found to be an accommodation entry provider as per the department’s search 3 | P a g e action as well as the statement of it’s authorized person which has been discussed in the reopening reasons. 6. Coupled with this, even the learned Assessing Officer appears to have issued section 133(6) notice to M/s. Oxygen Projects Ltd. Prasad More (1971) 82 ITR 540 (SC) and PCIT Vs. NRA Iron & Steel Co. (2019) 412 ITR 161 (SC) to conclude that learned lower authorities herein have rightly added the impugned unsecured loans of Rs.25 lakhs in assessee’s hands. Ordered accordingly. 7. No other ground or argument has been pressed. 8. This assessee’s appeal is dismissed. Order pronounced in the open court on 6th January, 2025 (SATBEER SINGH GODARA)